Answer:
by Randy Carey:
Whatever you determine it is based on your internal OFAC risk assessment. There are no specific regulatory requirements.
Answer:
by Jim Bedsole:
Well, technically there is a requirement. The requirement is that you not issue a cashier's check or money order either payable to or paid for by someone on the SDN listing. How you go about that, as Randy says, is up to your bank and your risk assessment. The regulations do not set any requirements for how you accomplish that. Banks with a very low OFAC risk tolerance will probably want to check all purchasers and payees against the OFAC list. Banks with higher risk tolerance may set a dollar threshold over which purchasers and payees will be checked. Some of that will also depend on your customers, geography, and prior history.
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