Checking OFAC Each Time For Repeat Customers

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Question:

When sending wire transfers for a customer who regularly sends wires, is it necessary to check this customer against OFAC each time, or would it be sufficient to check them each time OFAC posted an update? I understand the importance of checking the non-customer, but was a little dismayed at the prospect of checking customer Smith each time he wires.

Answer:

Unfortunately, in the climate of the examiner's world today, be sure to err on the side of caution. If your wire transfer people miss an update, and a name slips through, you will most assuredly hang for it. Though it's more work, it's much safer to check each time.

First published on BankersOnline.com 3/11/02