Do other banks do ongoing OFAC scans of employees? An initial OFAC scan is done at employment and IF the employee has an account here, there are ongoing scans of their names through the database scans; however the majority of our staff have accounts elsewhere so their names are not scanned.

We do it as part of the on boarding process and if they have an account. I would opine that risk is relatively low that a bank employee would be added to the SDN List for most community banks.

We do. We create a CIF for all employees to ensure they are checked for OFAC on each update. I agree with ABCbank that is is low risk, however better safe than sorry.