Answer:
As has been noted earlier, whether and what a bank checks against the OFAC list is a matter of risk management. There are types of transactions and types of persons that involve more risk of involving an OFAC-listed person that others. A domestic bank is a very low-risk person with regard to OFAC checking. Some banks might decide not to check domestic banks for that reason. However, the domestic bank's customer on such a wire is likely to present more OFAC risk, so that most banks check the beneficiary on outgoing wires and the originator on incoming wires. Many banks use OFAC filtering software or procedures in their wire transfer operations such that it is easy to check all parties to wire transfers -- including domestic banks.
First published on BankersOnline.com 10/08/07
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