OFAC Checks - Customers & Beneficiaries

If a bank only performs outgoing wires for customers, do the customers need to be run against the OFAC SDN List each time a wire transfer is requested? Does using FedLine make a difference?

Is there any guidance as to whom is exempt from OFAC checks, other than through an OFAC License, i.e., U.S. gov't, financial institutions, etc.

There are no exemptions under OFAC.
And there is no mandate that says you have to check anyone.
OFAC only says that you cannot do business with anyone on the list.
How you choose to ensure that you don't do business with anyone is up to you as a bank, based on what you consider your risk.

If you are only doing wires for customers and your customer base is checked on a regular basis, you would have a reason to not check them again.

Your bank should have a written OFAC risk assessment and an OFAC policy that spells all this out.

Thank you, MagicCity!

However, that could be different if the wired funds are going to someone other than sender (customer) and you should be checking the recpt.

i used to work for a mtg co that was owned by the bank, and on every closing with an outgoing wire we had to run an OFAC on all borrowers, sellers, POAs (if one was used), the receiving bank,and the settlement agent that we were using.