Answer:
OFAC compliance is risk based. The answer will vary from bank to bank and will depend upon the bank's OFAC risk assessment and its determination of its exposure to potential transactions involving individuals or organizations on the OFAC lists.
Geographic location and market area of the bank, types of loan products, individuals and organizations on the OFAC lists in the bank's market area - all should be part of the risk assessment process and will lead the bank to make such a decision.
First published on BankersOnline.com 5/6/13
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