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OFAC of 401K Participants

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Through our bank's trust department we manage several 401K plans. If a participant in the plan requests a distribution, do we need to OFAC the participant if they have no other accounts or relationships with the bank?

Your decision to check the participant's name against OFAC lists is, as all OFAC checking decisions, a risk-based decision that your bank should make, after analyzing the risks of paying funds illegally to a blocked party.

First published on 9/14/09

First published on 09/14/2009

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