OFAC checking a wire

On incoming/outgoing wires we have to perform an OFAC check. Do you check just the name or do you check the address too? Are you checking your customer also or not since it was already verified at account opening and during daily/weekly scrubs? Also under what regulation does this fall so I can refer to it?

There actually is no regulation which requires you to check your customers or transactions against the SDN List. The law requires that you do not conduct business with any entity on the SDN List. How you comply with the law is a risk based decision made by your bank.

My bank and most banks, check all information on a wire transaction prior to processing it.

All data in a wire should be checked. The OFAC software built into the system that processes your wire transfers should be savvy enough to conduct a thorough check, including the address.

“Chance favors only the mind that is prepared”. Louis Pasteur

You only need to check the name/entity. I scrubbed all over to find the requirement for checking address as well but I can't find any requirement. However, some institutions have it in their procedures to check the address also. I would refer to your OFAC risk assessment and use that as your basis. Remember if you don't put the address in your OFAC search, you still need to pay attention to the sanction countries. Keep in mind the travel rule too.

You have to check your customers at the time of the wire. The OFAC examinations procedures in the BSA FFIEC manual (page 158 #6 - 2nd bullet) states they will look timing and docmentation evidencing the searches.

While there is no requirement to check. I would not want to read in the newspapers that my bank sent a wire transfer to the Sudan or Burma in violation of sanctions or recieve a CMP for the same.

I'm with you Ed and I agree that is not a requirement and referencing the risk assessment is my answer to most of these types of questions, but if you have your wire transfers at that low of a risk rating where you choose not to check as many aspects of the wire that you easily can through automated or manual methods, I think your risk assessment is probably inadequate.

Isn't the easiest way 'to pay attention to the sanctioned countries' to check the address?

Also you do need to scan the originator-to-beneficiary information. A bank was penalized a couple of months ago for not checking that field in their wires.

If you have a computer system, just check every entity and all text on a wire all the time.