10/20/2008
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?
09/22/2008
Question: I?m not clear on the Red Flag requirements for identifying and tracking account risk, what?s involved?
09/22/2008
Question: We know that there is overlap between Red Flags and BSA/AML but what are the common functions?
09/08/2008
We have separate policies for our BSA program, OFAC and CIP. Can we combine them or are do they have to remain separate?
08/18/2008
Do you have to run an OFAC on the signers on a lease purchase for a county? Do you need an OFAC for the vendor and the signer for the vendor selling the merchandise to the county?
08/04/2008
Question: What should we do to comply with Red Flags risk assessment requirements?
07/21/2008
We have a question about whether or not we can perform an OFAC check on retirement/health savings plan beneficiaries. We have had some discussions that because the beneficiaries are not owners they have not given us permission to perform the OFAC check.
06/16/2008
We are aware that by law all transactions are required to be screened against the OFAC/SDN list. However, when a customer of the bank purchases a cashier's check payable to a U.S. government entity (i.e IRS, Franchise Tax Board, Board of Equalization, etc), are we required to screen them through OFAC check? What about attorney client trust accounts? I am assuming since U.S. government entities are well known, respectable organizations that they would be exempt from OFAC screening. I could not find anything detailing OFAC exemptions of any kind. Does verbiage such as this even exist in the OFAC policy?
06/09/2008
As required by law, we are aware that all transactions are required to be screened against the OFAC/SDN list. However, when a customer of the bank purchases a cashier's check payable to a US government entity (i.e IRS, Franchise Tax Board, Board of Equalization, etc), are we required to screen them through OFAC check? What about attorney client trust accounts? I am assuming since US government entities are well known, respectable organizations that they would be exempt from OFAC screening? I could not find any clear cut dialogue detailing OFAC exemptions of any kind. Does verbiage such as this even exist in the OFAC policy?
04/28/2008
Is there a regulation that states signers on a corporation do not need to be checked against OFAC?