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

Answered by: 
Brian Crow

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

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 BankersOnline.com 4/29/13

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First published on 04/29/2013

Filed under: 
Operations
Security
Filed under operations as: 
Checks
Debit Cards
IT
Security
Social Security
Filed under security as: 
Checks
Debit Cards
IT
OFAC
Security
Social Security

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