Skip to content

OFAC responsibilities

Question: 
Our bank has deposit accounts for small grocery stores that offer transmittal services through companies such as MoneyGram. The grocery stores deposit their transmittal cash intake, then the big transmitter company debits the funds in bulk via ACH. In that situation, what are our OFAC responsibilities?
Answer: 

If your institution has the information related to the originator (your customer’s customer), or has information regarding the ultimate beneficiary (the party who will ultimate receive the funds), you would have an OFAC liability for checking these parties to the transactions. The responsibility for checking the originator and beneficiary on the money transmittal for OFAC would fall on the two MSBs (the grocery store who receives the funds and the request to transmit -- the small MSB), and on the large MSB (Moneygram, or a similar company) who is sending the money transmittal to the end beneficiary.
-----------------------------
Learn more about Tim White’s webinar
OFAC for Community Banks

First published on 04/23/2017

Filed under: 
Filed under compliance as: 

Search Topics