Currently I am performing our annual BSA audit. I am in the process of reviewing incoming/outgoing wire transfers and part of that review includes checking to see if the WT department checked the beneficiary information against the OFAC software. My question is, it appears that if we are performing certain domestic wire transfers such as from one of our commercial customers to an escrow account held at another back or from one of our customers to an account held at another financial institution for benefit of an employee benefit account, how stringent are your programs in regards to verifying domestic information on OFAC. Now the above mentioned examples appear to be a "no-brainer" but I am wonder how other programs are structured as far as "Everybody and everything is verified" or "we maintain a list of repetitive transfers we know are not on OFAC"....I think with this being under hightened scrutiny maybe we (our bank) needs to clarify some of our procedures.

As our wires are inputted into the Fedline system, all sections are checked against OFAC. We get plenty of false hits. Do you use a Fedline system? Hope this helps you.

Are your wires checked using additional software? If so, which one? or are you saying that Fedline checks against OFAC?

Our procedures state that we are to be checking all incoming/outgoing wires against OFAC. However, during my audit I am finding this not to be the case, moreso with the incoming rather than outgoing. Do you check incoming? We use Bridger Systems OFAC software and yes we use the Fedline system.

MackenzieS: We just had a discussion about this yesterday. The conclusion we came to is that we only accept incoming wires for customers. All customers have been previously checked against the OFAC listing; therefore it does not need to be done again when a wire transfer is received.

Yes, but have you screened the originator of the incoming wires? They are not your customer. I know I am being the devils advocate on this, but we all are assuming that the bank originating the incoming wire has verified the information on their end before initiating the wire. But what if they didn't? That leaves you liable if the originator is on OFAC. It's a matter of determining what amount of risk we want to take and if it is worth the man-hours to verifiy this information. I for one think it is. In a time of heightened awareness of this issue, I don't see how we could not take that extra step. We too have verified (and verified and verified) our customers, it's the other end of the transaction that I am worried about. Another scary thought is that we too are learning and adjusting our program as this whole thing progresses, but I also just found out that some of the employees were only checking OFAC if the name appeared unusual (foreign).!!! So when I prepared my monthly newsletter I pulled out that old manual from OFAC (before the electronic systems) and pulled about 20 common names that you would not suspect would be on the OFACs list. I was hoping this would instill in them that it is not just foreign sounding names/companies that we should be checking.

We use the Fedline system for our wires and Bridger's OFAC tracker, which we have just recently set up. My next goal is to use the OFAC Tracker to scan our incoming wires on the Fedline. Are you using this to do a scan and if so get you give me any helpful information. Thanks