OFAC checks on incoming wires

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Question:

When an incoming wire comes in through a bank or the Fedwire, is our receiving bank required to do an OFAC check? Don't bankers and Fedwire procedures include OFAC checks on them before the wire is sent?

Answer:

How you handle incoming wires is a risk-based decision. If you feel comfortable risking an OFAC violation based on actions by other parties in the transaction chain, then a case should be made for that decision in your OFAC risk assessment.