Purchased Loans - OFAC/USA Patriot Act Compliance

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Question:

What would my bank's responsibility be for Patriot Act and OFAC compliance if we purchased a block of loans from another bank? Can we rely on the information gathered in the loan file or would it be best practice to run OFAC again?

Answer:

CIP does not apply to purchased loan, but OFAC does. You can never rely on another institution to cover OFAC for you.

First published on BankersOnline.com 2/09/09