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In Response To:
Thread Starter: BrianC
Title: Re: Who checks OFAC on credit and debit card trans?

Everything OFAC is risk-based. Remember that OFAC does not mandate when/how searches are performed. It only imposes penalties for processing a prohibited transaction.

In order to become an acquiring merchant, a financial institution has to agree to provide processing services to the merchant. As an issuing institution, you would have no way of preventing an authorization to a sanctioned entity unless you entered every name on the list into an authentication/fraud blocking program your processor provides. I know of no issuing bank doing anything like this. Similarly, I know of no bank that is reviewing the payee of every inclearing check that its customers write.