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OFAC Screening Local Organizations

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We are regulated by the FDIC. Are we required to OFAC screen any local organizations prior to making any charitable donations to them?

OFAC screening is a risk-mitigation technique. It is not required by any regulation, but it is considered a reasonable control designed to reduce the risk of completing a prohibited transaction with or for an OFAC-blocked party. Whether recipients of charitable donations should be checked is a risk-based decision your bank's management should make.

A factor to consider in that evaluation is the fact that there are purported charitable organizations that have been blocked by OFAC and/or implicated in terrorism funding efforts. So, at a minimum, your bank may decide to review any new organizations to which it has not previously made donations.

First published on 1/10/11

First published on 01/10/2011

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