OFAC Poll - Non Customer Inquiry

I'm sure this has probably been addressed, however I could not find any info in my BOL search. Can the readers let me know your policy/procedures relative to OFAC checks on non-customers cashing onus checks. Put simply, if a non-customer cashes a check at the teller line drawn on your institution does your FI conduct an OFAC inquiry? If so how is it documented? I appreciate any and all feedback.

At the institution I previously worked at we had the tellers/bankers use the free name check service available on Bridger Insight to conduct OFAC checks on non-customers.

http://bridgerinsight.choicepoint.com/free-services.htm

The results would be printed out and filed in the daily teller work. Any matches of 75 or more would be reviewed further before completing the transaction.

For checks exceeding $500, we do an OFAC check on the non-customer check casher. A checkmark and OFAC are written on the item.

It's in our bank policy to check non customers cashing checks.
The only documentation we have is the summary that prints next day for any partial/total matches. If they have what they think is a total match at the teller window, they request the assistant of the compliance officer, BSA officer, teller coordinator, and/or retail banking manager.

We OFAC the payee of any check $1000 or more that is cashed by a non-customer. The teller writes "ofac" with their initials in the upper left corner of the check.

Most state and national banks that I see are using a dollar threshold as described above by several posters. But that's only if the non-customer wants to cash an on-us check -- as indicated by your poll question, JD. Most of these same banks do not cash checks that are drawn on other banks for non-customers.

If you take this poll based on what you currently do, you will have the insight offered by a couple hundred BOL participants.

Our Bank was not previously verifying OFAC on non-customers. However, external compliance firm made recommendation during their review. We are now verifying OFAC on cashed checks for non-customers.

Our tellers use the OFAC inquery built into JackHenry for all non-customer cashing checks. The tellers also have a stamp that they put on the back of the check that has a place for ID type, ID#, expiration date, and the word OFAC that the teller initials by if no matches are found.

In reply to the posting that references Bridger / CHoicepoint free services link. DO NOT USE THIS LINK. I was interested in purchasing other services from them and asked about it and they verified that they DO NOT update the OFAC list that this checks against. This means that anyone who uses it is not getting a complete OFAC check verification on any name they type in.

As a matter of fact, they will be removing this link from their website offerings soon.