08/27/2007
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.
07/16/2007
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.
06/04/2007
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?
06/04/2007
When conducting wire transfers (incoming or outgoing) is it necessary to check bank names (both foreign and domestic) against the OFAC list?
05/28/2007
Do we need to check OFAC on the payees when the bank’s internal account payable department pays the bills for supplies, services, etc.?
04/16/2007
Is it a requirement to do an OFAC check on the seller of a property if we have the application for a new loan? Also, some say that they are actually doing OFAC screening on the attorneys involved with the transaction. Can you help?
03/05/2007
What does my bank need to do in regards to running OFAC on the purchaser and payee? Is there a requirement that an OFAC check should be run prior to conducting the transaction?
01/15/2007
Do we have to do an OFAC check on the payee of a cashier's check purchased by a customer?
11/06/2006
For OFAC purposes when we sell a cashiers check to a non customer we have begun to search OFAC on the remitter and the payee. If we sell to a customer do we have to check the remitter also since the person is our customer and they are checked at each new account opening and scanned through our data base monthly? We disburse loan proceeds by cashiers checks, do we need to check our self (the bank) on OFAC as the remitter?
09/25/2006
I have been posed with a record retention question regarding documentation that both a CIP and OFAC was completed on. These are internal procedures that our operations department have set up themselves and is above and beyond what I can find the regulation actually stating. Is there any guideline as to how long we need to keep such extra documentation?