05/10/2010
Does the bank have to do an OFAC check on checks that they write, or on contributions, bills, etc.?
05/03/2010
Do we need to check OFAC for payees when we originate an ACH?
04/19/2010
Regarding OFAC, if an account has been blocked due to a possible SDN match for a POD beneficiary, but the primary has been cleared, can the bank allow the primary to open a new account for himself, so that he may deposit funds while the POD beneficiary clears his name with the US Treasury OFAC division?
04/12/2010
If we do an OFAC check on our accounts (past 12 months) and there is one account hit, should we send the account name to OFAC? Do we need to find out the transaction of the account?
04/05/2010
Do we need to CIP and OFAC non-customers if we sell them money orders?
03/29/2010
What are the guidelines for checking prospective and current employees against the OFAC list? Not all employees have accounts with the bank or they would be checked on a weekly basis.
01/11/2010
The exam manual says that "relevant OFAC records" should be retained for five years. What should be considered "relevant OFAC records"?
12/14/2009
The exam manual says that "relevant OFAC records" should be retained for five years. What should be considered "relevant OFAC records"?
12/07/2009
When doing a wire transfer, how recent does the OFAC report on that have to be? I had a situation where a customer came in to sign the wire transfer form a week before the transaction was to take place, as they were going away on vacation, and that is when I took the OFAC. I took it the day that the wire transfer form was signed. Is this correct?
12/07/2009
Our internal auditor was asking how we monitor loan activity. We are not sure if the BSA person is responsible or if the loan department is responsible. Can anyone give me guidelines?