OFAC - Account Blocked Due to POD Beneficiary

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Question:

Regarding OFAC, if an account has been blocked due to a possible SDN match for a POD beneficiary, but the primary has been cleared, can the bank allow the primary to open a new account for himself, so that he may deposit funds while the POD beneficiary clears his name with the US Treasury OFAC division?

Answer:

While I know that OFAC has some rather interesting views on a POD beneficiary's legal interest in a deposit account, I don't agree that an account should be blocked based on a possible match of the beneficiary. I see no problem with opening a separate account for the blocked account's owner, as long as he or she is not an OFAC-sanctioned person.

First published on BankersOnline.com 4/19/10