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Run OFAC After The Deposit Account Is Opened?

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Question: 
When opening a new deposit account, not current customer, do we have to run the OFAC while the customer is sitting at our desk or can we run it after the account is opened? Do examiners have a preference on this?bri
Answer: 

The BSA Exam Manual states that the OFAC review can be either before or after the account is opened, but the institution could still be subject to penalties if the customer is able to perform any prohibited transactions before the funds are blocked.

New accounts should be compared with the OFAC lists prior to being opened or shortly thereafter (e.g., during nightly processing). Banks that perform OFAC checks after account opening should have procedures in place to prevent transactions, other than initial deposits, from occurring until the OFAC check is completed. Prohibited transactions conducted prior to completing an OFAC check may be subject to possible enforcement action.

First published on 09/23/2018

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