Are we required to run OFAC checks of domestic banks before sending an outgoing wire, orr are we only required to check international banks?
Through our bank's trust department we manage several 401K plans. If a participant in the plan requests a distribution, do we need to OFAC the participant if they have no other accounts or relationships with the bank?
Do we need to do anything to our OFAC policy in regard to the new international ACH transaction regulations? We already run all names through OFAC.
Do tellers need to run an OFAC check on a non-customer that comes in to cash a check on a customer’s account? The checks range anywhere from $5.00 to over $2500.00.
I need an opinion. This is about servicing non-customers and aggregating for BSA. We cash on-us checks for non-customers. We also sell money orders to non-customers. Our front end teller system completes an OFAC check prior to completing the transaction and our core database software reports and aggregates all cash transactions by SSN for BSA reporting and for AML tracking. Our new senior management has overridden my opinion that we should always collect a SSN on these non-customer transactions. What they are going to implement is a threshold value for these transactions. No social will be required for non-customer transactions under a certain dollar amount. The OFAC check will still be performed on the non-customer name. I feel that now we will be giving preferential treatment to non-customers where we will be tracking all cash activity on our customers.
Does CIP and OFAC pertain to opening a Certificate of Deposit? The customer already has other accounts in the bank.
Our customer database is checked against the OFAC list, DPL list etc. What does the acronym PLC list, stand for?
We are in a discussion with our BSA officer regarding this situation and need some direction. We currently sell cashier’s checks only to customers of our institution. We currently check OFAC on the payee in addition to the purchaser (our customer) which is covered by our routine OFAC check. Periodically, we have customers who purchase cashier’s checks for other persons, such as children, family members or others and they ask us to list these other names in the remitter portion of the checks. Do we have to check OFAC on this additional person even though we have checked the payee and purchaser? If we did, wouldn't we be exposing ourselves to collect CIP since we have allowed them to conduct a transaction via our institution? We are trying to establish the line between "memo information" as the memo information on a personal check, and "memo information" as transaction information that is covered by OFAC/BSA.
John Burnett, BOL Associate Editor
What would my bank's responsibility be for Patriot Act and OFAC compliance if we purchased a block of loans from another bank? Can we rely on the information gathered in the loan file or would it be best practice to run OFAC again?