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OFAC Screening & U.S. Goverment Agencies

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We are aware that by law all transactions are required to be screened against the OFAC/SDN list. However, when a customer of the bank purchases a cashier's check payable to a U.S. government entity (i.e IRS, Franchise Tax Board, Board of Equalization, etc), are we required to screen them through OFAC check? What about attorney client trust accounts? I am assuming since U.S. government entities are well known, respectable organizations that they would be exempt from OFAC screening. I could not find anything detailing OFAC exemptions of any kind. Does verbiage such as this even exist in the OFAC policy?

OFAC regulations do not define who you have to screen and who is exempt from screening. This is something that you would do internally in your own OFAC policy based on your risk assessment of the likelihood that a cashier's check payable to a U.S. government entity will create an OFAC violation.

First published on 6/16/08

First published on 06/16/2008

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