Answer:
To whom or what and when you apply an OFAC check is a matter of policy arrived at after analyzing the risk of non-compliance, the risk of doing business with a person on the OFAC list. There is no federal regulation mandating a check. Is it a good idea to check before paying money over to an account beneficiary? Absolutely! It's the last chance you'll have to prevent a violation. I'd recommend that you do so, even if you have checked the name against OFAC back when the beneficiary was first named (as some state regulators recommend).
First published on BankersOnline.com 11/19/07
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