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Wire Transfers - OFAC Bank Name Check

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When conducting wire transfers (incoming or outgoing) is it necessary to check bank names (both foreign and domestic) against the OFAC list?

Neither OFAC nor any of the banking regulators require any specific entities or individuals be checked for OFAC listing. This needs to be encompassed in your OFAC risk assessment. You need to assess whether there is sufficient risk of a violation occurring from a bank involved being on the OFAC list to warrant whatever steps would be necessary to screen for that. If your risk assessment determines the risk doesn't warrant the cost, then you won't screen for that. On the other hand, if you determine that it doesn't cost very much and the benefit outweighs the cost, you will screen for that. You just need to have your decision documented as part of your risk assessment. That's what the regulators will cite you for if you don't have it.

First published on 6/04/07

First published on 06/04/2007

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