Question & Answer

Question: What types of accounts must we watch in our OFAC compliance program?

Answer: First, think broadly. OFAC regulations apply to more than accounts. The requirements can apply to all property. This can include property stored in safe deposit boxes and other property such as a vessel used to secure a loan or that is the subject of a block.

Clearly your compliance program should deal with all accounts into or through which money flows. And the wire room needs to watch for wire transfers. But other areas of the bank should also be alert, including consumer and commercial lenders.

If it's any comfort, the OFAC regulations apply to more than just banks. All businesses and all people are subject to the rules. They just don't always know it.

Copyright © 1998 Compliance Action. Originally appeared in Compliance Action, Vol. 3, No. 10, 7/98