OFAC on Beneficiaries of an Employee Benefit Plan

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Question:

Is a trust company required to perform an OFAC search on the beneficiaries of an employee benefit plan?

Answer:

No financial institution is required to perform an OFAC search on anyone. The circumstances under which you search are based on your organization's OFAC risk assessment. Beneficiaries on qualified retirement plans for companies whose operations are entirely domestic should all be U.S. citizens or people who have legal permisssion to work in the U.S. and should be a relatively low risk group.

First published on BankersOnline.com 6/26/06