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I am in the process of revising our teller procedures to include checking all non-customer transactions against the most current OFAC list. I am still not clear on the non-customer transactions that should be checked. Could you clarify that for me and also, cash and checks both? My understanding is that tellers need to check on the following: all negotiable instruments sold (cashiers checks, money orders, wires, bonds, travelers checks). What about non-customer cashing an on-us check?

If the customer who wrote the check is on the OFAC list, you will doubtless have to refuse payment. If the non-customer who wants to cash the check is on the OFAC list, you doubtless should retain the check, refuse to cash it, and contact OFAC ASAP.

First published on 12/06/10

First published on 12/06/2010

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