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?
Does the bank have to do an OFAC check on checks that they write, or on contributions, bills, etc.?
Do we need to check OFAC for payees when we originate an ACH?
Regarding OFAC, if an account has been blocked due to a possible SDN match for a POD beneficiary, but the primary has been cleared, can the bank allow the primary to open a new account for himself, so that he may deposit funds while the POD beneficiary clears his name with the US Treasury OFAC division?
If we do an OFAC check on our accounts (past 12 months) and there is one account hit, should we send the account name to OFAC? Do we need to find out the transaction of the account?
Do we need to CIP and OFAC non-customers if we sell them money orders?