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OFAC Check on Plan Beneficiaries

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Question: 
We have a question about whether or not we can perform an OFAC check on retirement/health savings plan beneficiaries. We have had some discussions that because the beneficiaries are not owners they have not given us permission to perform the OFAC check.
Answer: 

You don't need permission to check names against the OFAC lists. If your institution has reviewed its risk of violating OFAC restrictions and has determined that it wants to mitigate that risk by checking names of plan beneficiaries, there is nothing stopping you from doing so. The most effective time to do an OFAC check of beneficiaries, however, might be just prior to paying anything out to them.

First published on BankersOnline.com 7/21/08

First published on 07/21/2008

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