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OFAC - Non-customer Cashing Customer’s Check

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Do tellers need to run an OFAC check on a non-customer that comes in to cash a check on a customer’s account? The checks range anywhere from $5.00 to over $2500.00.

The answer to this question hinges on what is called for in your OFAC compliance program. OFAC does not require you to check anyone. OFAC just requires that you appropriately freeze or reject (as applicable) any transaction with an individual on the OFAC list or related to any of the OFAC sanctioned countries or regions. How you go about complying with that mandate is left up to you to decide with your OFAC compliance program.

Cashing a check for a non-customer, if that customer is on the OFAC list, would be an OFAC violation, but that doesn't mean you have to check every non-customer against the list. Your compliance program should include a risk assessment and a determination of appropriate controls responsive to the risk. This assessment should include a review of the cost and effectiveness of controls being considered. If your bank compliance management determines that the risk involved in cashing a check for a non-customer who happens to be on the OFAC list is relatively small, and the cost for implementing a control such as mandatory screening of all non-customers cashing checks is relatively high, they may opt to instead assume the risk and not check. On the other hand, they may instead decide to implement screening but at a targeted amount, say for example requiring screening for any check cashing of more than $1,000. Whatever the decision, the decision and the rationale behind it should be documented as part of your OFAC compliance program and will be subject to review for reasonableness by your auditors and regulators.

First published on 8/17/09

First published on 08/17/2009

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