OFAC Sanctions Compliance – Does my bank need to check the OFAC list when selling cashier's checks and money orders? In the case of cashier's checks, do I need to check both the purchaser and the payee?

Compliance > OFAC
Q:  Does my bank need to check the OFAC list when selling cashier's checks and money orders? In the case of cashier's checks, do I need to check both the purchaser and the payee? As a mortgage lender, do I need to check both the purchaser and the seller's name against the Specially Designated Nationals list? Do I need to check their names against all of OFAC's other sanctions lists?
 
A:   Every transaction that a U.S. financial institution engages in is subject to OFAC regulations. If a bank knows or has reason to know that a target is party to a transaction, the bank's processing of the transaction would be unlawful. [09-10-02]
 
 
 
ADDITIONAL INFORMATION – This Q&A was included in the U.S. Department of the Treasury’s online Resource Center for OFAC - Sanctions Compliance, which may be found here:  https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_compliance.aspx
 

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