Are banks required to search the OFAC lists on domestic banks when wiring funds?
Use of the Category ?Other?
Several facts about the 78 depository institution SARs and 10 SAR-MSBs with cooperative narrative references appear noteworthy.
Upon OFAC verification, can a bank open a new account on a Mexico Corporation?
When should lenders order OFAC on loans? We are running them twice, once when the application is received (why go through the process if we get a hit) and once again after docs are ordered and before the loan is booked. Is there any standard we should adhere to?
Should we run prospective employees against the OFAC List? Do we need their permission to do so? As CO I say we should, but my HR manager disagrees.
Would it be advisable to check a non-customer who is requesting a cash advance on their credit card against the OFAC list? The bank limits these types of transactions to $1,000.
When conducting wire transfers (incoming or outgoing) is it necessary to check bank names (both foreign and domestic) against the OFAC list?
One of our branches has a customer (a builder) writing large checks to their employees on a weekly basis ($5k-$7k). The builder comes in with the employee to cash the check. The employee endorses first, then the builder endorses and cashes the check. The builder is a known customer, so the tellers do not get identification on him and since he endorses after the payee they are not getting the payee's identification. They are, however, checking the payee/employee against OFAC. Bank policy states that we check OFAC on all non-customer payees over $1000 and record identification on non-customers and payees over $3000. I am getting a match on two of the three employees. I am 90% sure that it is a false positive, but I cannot confirm or deny it is a valid hit unless I can compare their identification information to the hit. The branches administrator was notified that the branch is not following bank policy and that identification needs to be obtained on the payees. The branch defends their actions stating that, technically, they are not making an exception since the employee and builder are presenting on-us checks we are able to verify funds and also that the last endorser is vouching for the non-customer. I understand their concern because it is technically true, but as the Compliance Officer I also understand that, per OFAC, banks must block transactions that are by or on behalf of a blocked individual or entity. If this branch continues to willfully ignore the intent of the customer, which is to give money to this employee, we will end up with severe penalties if the payee is found to be a blocked individual. This is a risk I would rather the bank not take. Can you shed some light on the subject?
Do we need to check OFAC on the payees when the bank’s internal account payable department pays the bills for supplies, services, etc.?