How would you respond to a borrower who insists he or she gets SCRA protection based on employment overseas with the State Department or one of the federal law enforcement agencies (e.g., FBI)?
Do I need to do an OFAC check for a guarantor?
How often do we need to do an OFAC check on a current customer if one was done previously on a loan? Do we need to do it every time there is a new loan?
Is the 314a request the same thing as the OFAC list? I was told they were 2 separate things and I was also told that the 314a requests are the new names that will be included on the OFAC list. Could you please tell me which one is correct?
The annual Money Laundering Enforcement Conference co-sponsored by the American Bankers Association and the American Bar Association is always fertile ground for new ideas on BSA program management
Aren't we suppose to verify that the people making loan payments are not on the OFAC list? What I mean by that is, the maker of the check that is making the loan payment is not on the OFAC list.
We are looking for recommendations/best practices regarding loan proceeds/payees and OFAC. Is it necessary to check OFAC for those entities receiving proceeds from a loan?