Ofac search on new hires

Is anyone doing an OFAC search on NEW JOB APPLICANTS or doing a search AFTER HIRE?

JanDan:

Although it's not yet a common practice, many institutions are conducting background investigations on every insider and third-party service provider that may have access to consumer data -- as part of their Information Security Programs. This background check should include OFAC checking.

We have built that into our procedures. It's yet another way of covering yourself!

Our Personnel Dept., Manager insists on NOT doing an OFAC search on new hires......I think we should

Do you open accounts for new hires? If so, 326 is not going to give you a choice on checking OFAC.
That being said, I am very curious as to what otherworldly logic your Personnel Manager is using.

It's hard to believe after the BONY debaucle that anyone would question an OFAC search on ALL employees! Since 1999, Know Your Customer has always meant Know Your Employee as well.

In reply to:

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Our Personnel Dept., Manager insists on NOT doing an OFAC search on new hires......I think we should

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Has your manager explained why he/she does not want to conduct this check?

If it's an issue of money, you can do a one-name-at-a-time check for free on the Bridger Website at Bridger OFAC Compliance

Just be prepared if the names you are searching are Hispanic or Middle Eastern as there are a lot of "common" names to be found on the OFAC list.

Now, if you are located in California, your Manager may not have a choice as the Dept. of Financial Institutions now requires banks to have a Personnel Policy in place that provides for background checks to prevent terrorists from being hired at the bank.