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?
How often does an OFAC need to be run? I know our database is automatically scanned, but we are running a new one for each new loan even if they are a current customer. Do we need to do this?
Question: I?m not clear on the Red Flag requirements for identifying and tracking account risk, what?s involved?
Question: We know that there is overlap between Red Flags and BSA/AML but what are the common functions?
We have separate policies for our BSA program, OFAC and CIP. Can we combine them or are do they have to remain separate?
Do you have to run an OFAC on the signers on a lease purchase for a county? Do you need an OFAC for the vendor and the signer for the vendor selling the merchandise to the county?