OFAC on credit card authorized users

Posted By: Calmeida12

OFAC on credit card authorized users - 07/07/16 06:27 PM

Does anyone know if OFAC needs to be run for credit card authorized users? Thank you.
Posted By: John Burnett

Re: OFAC on credit card authorized users - 07/07/16 07:05 PM

OFAC doesn't require you to run anyone by its SDN List. It only cares that you not violate OFAC regulations. Your bank should do a risk-based analysis of authorized users of credit cards to figure out whether you want to scan such names against the list.
Posted By: Calmeida12

Re: OFAC on credit card authorized users - 07/07/16 07:25 PM

Thank you John. My next question is: What about CIP, should the 4 basic CIP items be collected for credit card authorized users?
Posted By: John Burnett

Re: OFAC on credit card authorized users - 07/07/16 07:32 PM

The regulation would not require it, because as authorized signers these people are not customers. But if your CIP requires it, you have to abide by those in-house policies.