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#588474 - 07/26/06 01:58 PM OFAC on existing clients opening new accounts
JRines Offline
Junior Member
Joined: May 2005
Posts: 47
Florida
A debat has begun about wether or not it would be necessary to complete an OFAC verification on existing customer prior to estanblishing another new account even if you verify your institutions entire customer database each night?

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#588475 - 07/26/06 02:36 PM Re: OFAC on existing clients opening new accounts
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
It would seem to be overkill.
If you scrubbed your database last night and the next day an existing customer opens another account, it is highly unlikely that they would be on the OFAC list.

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#588476 - 07/26/06 02:41 PM Re: OFAC on existing clients opening new accounts
Oursisnottoreasonwhy Offline
Platinum Poster
Oursisnottoreasonwhy
Joined: Nov 2004
Posts: 506
Central Illinois
It would seem to be a very low risk transaction, however you should follow your OFAC Policy and Procedures.

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#588477 - 07/26/06 03:35 PM Re: OFAC on existing clients opening new accounts
Big Dog Offline
Power Poster
Big Dog
Joined: Mar 2005
Posts: 2,659
Kennel
Remember that you are doing the OFAC on the Customer, not the account. If you have already done the OFAC scan, and your system scans all customers each night, to catch the OFAC updates, then an additional OFAC check when opening a new account would not be necessary.

If your procedures/policy states that an OFAC check must be done on each new account opened, then you will need to get those changed.

(I also saw your ACAMS listserve message, but it is easier to answer here)
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