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OFAC and Minors

Question: 
Should OFAC checks be run on a minor?
Answer: 

by Brian Crow:

OFAC does not mandate when and on whom a search is to be performed. It imposes penalties if you conduct a transaction for a sanctioned person. Your OFAC risk assessment should dictate when searches are to be performed. From a risk-based perspective, I do not see a good reason for excluding minors as there is nothing preventing the US Treasury from adding a minor to the OFAC list.

Answer: 

by Andy Zavoina:

If your bank has good systems and successfully trained staff to do the OFAC checks, why muddle up a sound process with an exception which still carries risk with it, albeit a minor amount?

First published on 11/27/2022

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