OFAC - Checking Minors Against the SDN List

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Question:

This question is in regard to OFAC. Is there any stipulation when opening a new account (new customer(s)) that contains a minor, that you should not have to worry about checking a minor against the SDN list? Let's say you open Jr. Savings Accounts, what should be the bank's policy and procedures for checking the SDN list at account opening?

Answer:

The bank's policies and procedures for checking the OFAC list should be derived from its formal OFAC risk assessment. There are no "standard" answers as to how and when the bank should check the list as a condition of opening an account. You may be able to rationalize that your bank's risk profile combined with the presumed innocence of small children is an adequate rationale for not checking the list in this circumstance.

First published on BankersOnline.com 5/1/06