OFAC

OFAC

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Question:

I am in the process of revising our teller procedures to include checking all non-customer transactions against the most current OFAC list. I am still not clear on the non-customer transactions that should be checked. Could you clarify that for me and also, cash and checks both? My understanding is that tellers need to check on the following: all negotiable instruments sold (cashiers checks, money orders, wires, bonds, travelers checks). What about non-customer cashing an on-us check?

Answer:

If the customer who wrote the check is on the OFAC list, you will doubtless have to refuse payment. If the non-customer who wants to cash the check is on the OFAC list, you doubtless should retain the check, refuse to cash it, and contact OFAC ASAP.

First published on BankersOnline.com 12/06/10