OFAC Question

We manually check updates to the SDN list by running the names through our customer database. With the recent descriptor information changes, should ALL names appearing after the (-to-) be checked (i.e. all aka's)?

Yes. An individual may use an alias, rather than their real name, to do business with you.

A follow up question: On the SDN List, it seems in looking through it that the AKA's appearing after the first listed name on the alphabetical list are cross-referenced, or listed elsewhere as a first listed name themselves. Is this correct? I'm trying to determine whether doing a search for each first listed name will be a complete and thorough search.

And while we are on the OFAC subject, I have additional concerns. To what depth are we required to go to perform this verification? Obviously, we should check our customer accounts of record following each OFAC update. Should we also be manually reviewing historical wire transfer records? What about cashier's check and ACH records? What are our expectations for due diligence here. Outside of scanning our deposit records, everything else is a manual effort.

Beth, in response to your follow up question, I checked all of the a.k.a.'s on the first page of the October 12 SDN List and they were all listed later in the the list as a first listed name. A search for each first listed name would appear to be a complete search. A word of caution,if you are looking for a name that is hypenated (-) or contains an underscore (_) make sure you are reviewing all sections of the list which contain the letters in the name. At some points the list seems to not be in alphabetical order (see pages 4-6).

Brenda, the intent of the OFAC list is to block certain transactions and seize assets of existing accounts. Searches of completed cashier's check transactions, ACH and outgoing wire transfers are not necessary. If the funds were wired into an currenting existing account, a search of your current records should reveal the account. Of course all future transactions should be checked on an ongoing basis.

Sam - -Related to the OFAC list, do I understand that as long as we search our existing customer accounts against the most recent OFAC list, that our due dilligence is complete? So, as far as our tellers and new accounts reps are concerned, are they not required to check the OFAC list when they open a new account, sell a cashier's check, Money Order, Travelers cheques over $3,000 to non-customers? Just want to make sure that our bank is doing the right thing.

Please clarify once again.

As Sam noted, all future transactions should be checked (such as new accounts at the time of opening) on a go forward basis, using all names and entities on the OFAC list.

Mary Beth:

Any suggestions on how to efficiently have tellers do this for non-customer transactions such as Cashier's Checks, outgoing wires, MOs, TCs, etc.? Identification on most is not required unless the amount is $3,000 or more.

Thanks,

Marie