CIP & OFAC - Sale of Money Orders to Non-customers

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Question:

Do we need to CIP and OFAC non-customers if we sell them money orders?

Answer:

The sale of a money order is not the opening of an account under the CIP regulations at 31 CFR 103.121. Your bank should have a comprehensive OFAC risk assessment that covers each potential transaction type, including the sale of money orders. Whether to complete an OFAC check of the purchaser of a money order should be a risk-based decision reflected in a management policy.

First published on BankersOnline.com 4/05/10