OFAC screening on domestic banks

Is it common to perform OFAC screening when the receiving bank or an intermediary bank is a domestic bank?

Most systems automatically screen everyone involved with a wire, so yes.

For us it is a manual process. But we do OFAC domestic banks. We went back and forth with the NCUA and it just became easier to OFAC everyone every time. If I can make out a name/business I OFAC it. Better safe than sorry and I am already in there OFACing other things anyway.

(shakes head).... I sure hope you run the National Credit Union Administration through OFAC every time you need to send a remittance to them.

It's one thing to have an automated system that screens all fields. It's quite another to require a MANUAL screen every time you need to send a wire to Bank of America. OFAC does NOT require that, and your OFAC program should be risked based.

But if that's how your NCUA examiner wants to play, then I would suggest that, before you allow them to plug in their laptop, get a cup of coffee, or anything else, you make them wait while you run NCUA and the examiner's name through your OFAC screen.

Yes - I am being snarky but I hate when common sense goes out the window.

I tend to agree with PR. If you're manually screening for OFAC compliance, there is zero benefit to screening US domestic banks.

With anywhere from 3-10 wires a day, it's hardly cumbersome.

I get it though. But after being told one year it was fine as long as we put it in our policy that we accept the risk of not checking domestic banks and then the next year having them on our case about it, it just wasn't my time and effort to argue it.

And honestly if they weren't on our case about it, I probably wouldn't either!

That is only for wires how about; new accounts, lending, accounts payable, ACH...

What are the chances of a domestic bank being on the OFAC list? Do you think a domestic bank would still be open if on the OFAC list?

We don't OFAC domestic banks, have it in our policy and our examiners haven't said anything about it.

One would hope none... That was the same case I made with the NCUA. If there were doing bad things, pretty sure they wouldn't be sending wires to a small CU in OK...

Ditto. And we don't. And our risk assessment reflects that fact.