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Method to Properly ID Old Municipalities (OFAC)

Answered by: 
Randy Carey
Brian Crow | CAMS

Question: 
I am working on a loan to a local municipality in Pennsylvania that was formed by court order in 1857. They have no record of the order at the Township and it pre-dates our state's records. Is there a method to properly ID old municipalities like this that will comply with OFAC requirements?
Answer: 

Randy Carey

Are you saying that you think that a municipality located in the United State of America might be on the OFAC list and you are trying to run an OFAC check on the municipality? I really must be misunderstanding your question.

Answer: 

Brian Crow

Additionally, if the person submitting this question meant to say "CIP requirements" units of government are excluded from the definition of customer so CIP wouldn't apply.

First published on 06/20/2021

Filed under: 
Lending
Filed under operations as: 
BSA
OFAC

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