If your customer has multiple dba names do you do a Part I for each one?
Why would my customer be making repeated purchases of Bitcoin?
Is OFAC training a required course for our board of directors annually?
Could you please tell me where/when I can find up-to-date OFAC lists?
SAR Filing Leads to Embargo Investigation
Do you have to run OFAC on non-customers presenting VISA debit cards for payment of social security or tax refunds?
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?