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#940018 - 04/10/08 09:12 PM OFAC & Govt. Agencies
moola40 Offline
Member
Joined: Nov 2003
Posts: 98
A recent discussion has arisen in regards to checking govt. agencies against the OFAC list. Is it a requirement of OFAC to check these agencies when opening an account or not. Please someone settle this for me.

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#940028 - 04/10/08 09:20 PM Re: OFAC & Govt. Agencies moola40
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
There is no requirement to check anyone against the list, you just don't want to be found to have done a transaction with someone on the list. For this reason you should do a risk assessment and look at various factors, such as your location, customer base, products and services, etc. to determine (and have BOD approval) on what you should be checking.

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#940068 - 04/10/08 10:25 PM Re: OFAC & Govt. Agencies devsfan
i*sam Offline
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i*sam
Joined: May 2007
Posts: 166
Southern California
Are you talking about US government agencies? The OFAC list is all foreign entities. I would say there is minimal risk in dealing with a US government agency and would not run them against OFAC.

If you mean foreign government agencies and people working for those agencies, I would consider them high risk and ALWAYS check them for OFAC (and World-Check to pick up on any PEP/SFPF).

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#940224 - 04/11/08 12:52 PM Re: OFAC & Govt. Agencies i*sam
Hrothgar Geiger Offline
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Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
Originally Posted By: i*sam
... The OFAC list is all foreign entities...


I suppose that depends on your definition of 'foreign'. The OFAC lists contain a number of US entities; individuals, companies and charitable organizations.

Also,..., others have done an excellent job of explaining the compliance principles behind a 'risk-based' approach to sanctions checking.

I will add an operational/tactical perspective. It could be more trouble than it is worth to add exceptions to your systems and procedures.

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