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Checking Employees Against the OFAC List

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What are the guidelines for checking prospective and current employees against the OFAC list? Not all employees have accounts with the bank or they would be checked on a weekly basis.

There are no guidelines besides the ones your bank sets up based on its analysis of the risk of making an OFAC-prohibited payment. It's probably fair to say that there is a low or very low risk that an employee of your bank will be on the OFAC list, so your bank may decide that it's sufficient to check every new hire candidate against the list before extending a job offer, and follow up on current staff on some infrequent but periodic basis.

First published on 3/29/10

First published on 03/29/2010

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