09/11/2006
Our recent examiner said we must check OFAC on all parties included on each wire transfer. We were a little confused on this one, can you help?
07/17/2006
We cash payroll checks for one of our business customers. The employees of this company are not our customers. Do we need to do an OFAC screen on each of these workers when they come to our bank to cash their payroll checks?
06/26/2006
Is a trust company required to perform an OFAC search on the beneficiaries of an employee benefit plan?
06/12/2006
Can you cash an on us check for a person that is on the OFAC list? Do you block the actual customer’s account when this occurs?
05/29/2006
Once an account holder is deceased on a POD account, does OFAC need to be run on the beneficiaries before funds are transferred to the beneficiaries?
05/01/2006
This question is in regard to OFAC. Is there any stipulation when opening a new account (new customer(s)) that contains a minor, that you should not have to worry about checking a minor against the SDN list? Let's say you open Jr. Savings Accounts, what should be the bank's policy and procedures for checking the SDN list at account opening?
04/17/2006
I am assuming the bank is required to check the OFAC list prior to cashing a check drawn on us but issued to a non-customer. Am I right?
03/20/2006
We buy loans from another institution and that institution retains the servicing obligation. Do the borrowers become our customers for BSA and OFAC purposes? This is basically a general ledger transaction.
02/15/2006
On September 26, 2001, the Treasury Department's Financial Crimes Enforcement Network (FinCEN) established a FINANCIAL INSTITUTIONS HOTLINE, 1-866-556-3974, for financial institutions to voluntaril
01/23/2006
At our bank we have to do screen prints of when we do OFAC checks. How long do you advise that we hold these copies for?