Thread Starter: Anonymous
Title: Re: OFAC’s missing link! Please try this!
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Please, try this OFAC test yourself, and tell us your results with a post in this forum.
1. Regulators, stop reading – no fair.
2. Pull the most recent OFAC list from the OFAC’s website (http://www.ustreas.gov/offices/enforcement/ofac/sdn/index.shtml).
3. On OFAC’s own most recent list, jump down to around the last 25 pages or so. Look for the section that ends with the word Zimbabwe in brackets, like this: [ZIMBABWE]. Names after Zimbabwe start back in the “As” again (not the Zs) and all have quotation marks around them, like below.
ZVINAVASHE TRANSPORT
[ZIMBABWE]
"ABD AL-HADI"
"'ABD AL-MUHSI"
"'ABD AL-RAHMAN"
4. Go to your core processor (especially if you are own Jack Henry) and try to perform an OFAC search of several of the names appearing on, roughly, pages 394 to 416. If you get matches on some of them, don’t worry…just keep trying. Try at least a dozen and see if you can find some that do not show as matches in your system. In mine, the second name above, "'ABD AL-MUHSI" is “no match.” Jack Henry assures us that everything is fine. So does IT.
This section is not the PLC list. Our PLC list is already fixed and all show as matches. This section is an alphabetical listing of names in quotation marks that belong to several of the OFAC programs, including, for example: SDGT, SDNT, SDNTK, DRCONGO, etc. etc. etc. On or around page 416, the list changes to Kor., Vessels, etc. – I sampled some from each of those last few sections, and they are showing as matches. So it’s only pages 394 to 416 (approximately).
Again, it is not every name on the list – but many, many of them – that are not showing as matches.
Does anyone know a valid reason why I would NOT have to check these names? I know no regulation requires checking the names (we just have to avoid doing business with them), but our policy requires checking the OFAC list and I'm uncomfortable with not checking about 5% of it.
Does anyone have an idea how I can correct this? IT, Jack Henry, and my BSA consultants are all drawing a blank.
Thank you!
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