Check Cashing MSB-Names Against OFAC List

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Question:

Does a check cashing MSB have to check names against the OFAC list? The MSB does no other MSB activities but check cashing. I have called FinCen numerous times and they have not returned my call. Someone at OFAC referred me to Title 31 which also did not address or answer my question.

Answer:

OFAC applies to everyone, not just banks. If you doubt it, see the fines they have levied against individuals for possession of Cuban cigars. However, there is also no law that says anyone has to check anything against the OFAC list. It is all a matter of risk management.

First published on BankersOnline.com 10/24/11