OFAC Check for DBA

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Question:

Is there a requirement to run an OFAC check on a DBA? For example, John Doe DBA ABC Store. Do I need to run an OFAC on John Doe and ABC Store, or simply John Doe?

Answer:

The purpose of running an OFAC check is to avoid completing a transaction with an OFAC-blocked party, not to comply with a specific set of rules. Whether your institution will require that its personnel run OFAC checks on the owner of a sole proprietorship or on the fictitious name he or she uses is a matter of risk management -- Will a check of the owner's name and not the fictitious name sufficiently reduce your OFAC risk?

Don't forget that persons other than individuals can "do business as" a fictitious name, too, so your question really should expand to cover situations like "Doctors Associates Inc. DBA Subway Restaurants."

First published on BankersOnline.com 1/10/11