Run an OFAC for Each New Loan?

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Question:

How often does an OFAC need to be run? I know our database is automatically scanned, but we are running a new one for each new loan even if they are a current customer. Do we need to do this?

Answer:

When a bank handles OFAC checks in the way you've described, it's done to ensure that there is one procedure for all transactions. That can lead to simpler instructions and more uniform compliance to policy with reduced training demands. If your customer base is regularly scrubbed for OFAC suspects, doing a check on each new loan for existing customers appears to be redundant.

First published on BankersOnline.com 10/20/08