Run OFAC on Newborn? (Savings Account for Baby)

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Question:

Do we need to run OFAC on a newborn baby whose mother or father have opened a savings account for the baby? We do have the Social Security number for the newborn.

Answer:

Running OFAC is purely based on the bank risk assessment and policies that the bank has developed to mitigate the risk of entering into a transaction with someone on the OFAC list. Since a baby cannot contract for an account, it must be held in a UTMA account or on a similar custodial basis.

First published on BankersOnline.com 8/6/12