I am curious, even with all of the attention OFAC sanctions has received in the past year, does anyone allow any accounts to be exempt from OFAC verification because you "know your customer"? Does anyone maintain an exemption list in your wire transfer department for repetitive incoming/outgoing wires from longtime customers that your bank historically has known is not on any of these lists? Should this be the judgement call of any particular officer of the bank?

The way I read the CIP proposed rules, you HAVE to check the list, no exceptions. With CIP, you have to form a "reasonable belief" that you know the true identity of your customer. If a customer has been with the bank a long time and the come in to open a new account after the effective date, you have to check. With wires, If you have a repeat customer, I guess it depends upon the risk you want to take. If they aren't showing up on the list, maybe you can check every other time. But what about the beneficiary of the wire? If the beneficiary is different every time, why not go ahead and check the customer as well. People go on and come off all the time. Maybe my view is a little on the extreme side, but I think that the time for CIP is also the time for CYA

The "silent cell" in NY reinforces why this wouldn't be an acceptable practice. Names get added to the OFAC and Control lists so ongoing checks will be necessary. Exemptions are not an option.

I agree, the list has to be checked each time as it is continually subject to revision.

I happen to agree with everyone in this forum. You have no choice, current customer or not.