Incoming IAT Debits and OFAC

How are FI's handling incoming IAT debits when you are unable to complete OFAC screening by EOD? The OFAC Letter issuing revised guidance, dated 3/18/2009, says that the suspect transaction can be removed from the batch for further investigation, but what do you actually do with it? 99.9% of the time we are simply waiting for clearing data from our clients, but sometimes they are not timely.

You have two choices. Either accept the risk and post the transaction or reject it. Personally, given the potential fines involved with OFAC, I'm not a big proponent of accepting the risk for a $9.99 PayPal transaction.

Thank you!

If our bank cannot clear it that day, we reject it based on risk.