If we have a Middle initial...say "John Q. Doe"...this is how the client's name appears on the his DL. Do the OFAC regs REQUIRE that we the Bank demand to know what the middle initial stands for...in order to check John Quincy Doe with OFAC? If we do not check for the middle name, are we out of compliance? Please advise.
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.
Is there any regulation that requires obtaining/retaining a copy of a social security number and drivers license for any and all checks cashed for a non-customer, whether it is an on-us check or a check from a non-customer to an existing bank customer? We do understand the need to pull OFAC on all transactions that involve a non-customer no matter the amount of the check. It is very time consuming to make copies of IDs and the checks. Are examiners going to the extreme? If we check identification, it seems that with the OFAC that should suffice. Are all banks required to do this now?
What information in a bank's data base is required to be screened against OFAC periodically? For example are guarantors, signatories and accounts payable vendors required to be scanned?
Is there a requirement to run an OFAC check on a DBA? For example, John Doe DBA ABC Store. Do I need to run an OFAC on John Doe and ABC Store, or simply John Doe?
We are regulated by the FDIC. Are we required to OFAC screen any local organizations prior to making any charitable donations to them?
I am in the process of revising our teller procedures to include checking all non-customer transactions against the most current OFAC list. I am still not clear on the non-customer transactions that should be checked. Could you clarify that for me and also, cash and checks both? My understanding is that tellers need to check on the following: all negotiable instruments sold (cashiers checks, money orders, wires, bonds, travelers checks). What about non-customer cashing an on-us check?
When issuing cashier's checks, does the party the check is being issued to have to be checked against OFAC?
Is it wriiten anywhere for BSA that an OFAC check has to be done on a payee of a monetary instrument who is a non-customer?