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Checking OFAC Require Middle Name?

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If we have a Middle initial...say "John Q. Doe"...this is how the client's name appears on the his DL. Do the OFAC regs REQUIRE that we the Bank demand to know what the middle initial stands order to check John Quincy Doe with OFAC? If we do not check for the middle name, are we out of compliance? Please advise.

There is not now, nor has there ever been an explicit requirement for banks to check the OFAC list. It is a "risk based" decision that varies from bank to bank. Your bank is entitled to make its own decision about whether it is necessary to incorporate middle names or initials in its searches.

I would make the observation that you are not assuming more risk when you fail to use the initial or middle name, you are simply increasing the risk that you will get a "false positive" and waste time discounting the match.

First published on 12/10/12

First published on 12/10/2012

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