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Run OFAC on Non-Customers for VISA SS/Tax Refund?

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Do you have to run OFAC on non-customers presenting VISA debit cards for payment of social security or tax refunds?

OFAC does not "require" that you perform any checks on anyone at all. However, the bank can incur significant fines if it transacts with an individual or entity on the OFAC list. Each institution must make a risk-based decision for which transactions it will compare against the list, and at what dollar thresholds.

First published on 4/29/13

First published on 04/29/2013

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