OFAC on Credit Bureau Report

If we get an OFAC report on our Credit Bureau Report, do we still need to do a separate OFAC??

That depends on what your BSA Policy and procedures say. If we are pulling a credit report that has an OFAC search on it, we don't require them to pull a second inquiry from another source.

So if our BSA policy says we need to check OFAC on xxxxxxxx site, we are out of compliance if we use the OFAC from the credit report???

Yes. You're not in violation of any law, you're just not doing what you said you were going to do. Change the policy.

I agree with Ken. Keep the policy generic - "We will perform an OFAC screen before account opening" or something to that nature. That way if you switch vendors, you don't have to remember to change the name in the policy, take the policy to the board to have it reapproved, etc.

Definitely keep the policy generic (for the reasons given by "bcompliance." Details, such as accessing OFAC data via the credit bureau or some other method, go in your procedures. The procedures need to be kept current, of course, but there's no heavy lifting involved -- no scheduling time for a board presentation, no board resolution, etc.

While it is good to keep the policy generic, every end point for an OFAC check should be outlined in your most current OFAC risk assessment. Within that risk assessment, your mitigation factors (i.e., how the OFAC check is performed) should be thoroughly outlined and supported within your OFAC procedures.

Just throwing this out there but does your bank know the specifics of the OFAC filter of the Credit bureau?

Do they support the same misspellings as you may have in policy?

Do they just support 100% match?

if you have a sharp examiner (or PITA) you may need to answer such questions