Enhancements to OFAC/New Consolidated OFAC Search Screen

CMPs: 4902, 6041, 6042, 6090, 6205, 6901, 7054, 7055, 9394

CIM GOLD Version 7.9.10

A new, improved, consolidated version of the Miscellaneous > OFAC Search screen (shown below) is now available in version 7.9.3 of CIM GOLD. The consolidated version of this screen contains the same three basic search fields (Last Name, First and Middle Name, Business Name) and <Search> button as the standard OFAC Search screen, but also displays an OFAC History field group to view system history for previously run OFAC searches.

Contact GOLDPoint Systems if your institution is ready to start using the improved OFAC.

Setup

In order to use the consolidated OFAC Search screen, institution options DFFN and NRCV as well as the Consolidated OFAC Report (FPSDR338) must be set up for your institution. Reports FPSDR169, FPSDR213, FPSDR216, FPSDR226, FPSDR238, FPSDR334, and FPSDR335 are obsolete and must be turned off for your institution before using this screen.

Additional institution options can be applied to help reduce the number of false positives in OFAC searches. If these options (all under the OP31 category) are set, they will be used on every OFAC search processed by your institution.

•OFF1: Only Exact First Names 1st Word - If this option is set, an individual will not be matched in OFAC searches if the first word of the customer's first name is not identical to the first word of the sanctioned first name. This option is ignored when the customer name may be either an individual or an entity, or when the sanctioned name is not an individual.

•OFFA: Only Exact First Names All Words - If this option is set, an individual will not be matched in OFAC searches if the entire customer's first name is not identical to the entire sanctioned first name. This option is ignored when the customer name may be either an individual or an entity, or when the sanctioned name is not an individual.

•OFO1: Only Exact Org Name 1st Word - If this option is set, an entity will not be matched in OFAC searches if the first word of the entity's name is not identical to the first word of the sanctioned name. This option is ignored when the name may be either an individual or an entity.

•OFOA: Only Exact Org Name All Words - If this option is set, an entity will not be matched in OFAC searches if the entire entity's name is not identical to the entire sanctioned name. This option is ignored when the name may be either an individual or an entity.

•OFML: Last Name Match If The 1st Word Matches - If this option is set, an individual will be matched in OFAC searches if the first word of the customer's last name is identical to the first word of the sanctioned last name.

•OFL1: Only Exact Last Names 1st Word - If this option is set, an individual will not be matched in OFAC searches if the first word of the customer's last name is not identical to the first word of the sanctioned last name. This option is ignored when the customer name may be either an individual or an entity, or when the sanctioned name is not an individual.

•OFLA: Match Entire Last Name - If this option is set, an individual will not be matched in OFAC searches if the entire customer's last name is not identical to the entire sanctioned last name. This option is ignored when the customer name may be either an individual or an entity, or when the sanctioned name is not an individual.

New OFAC History field group

This new field group (see example below) is available to view system history for previously run OFAC searches.

The top list view in this field group displays information about all OFAC searches that match the criteria indicated in the search fields above. Use these search fields to indicate a range of dates (Start/End Date), a specific Source* for the search, and/or a name of an employee who performed the search (Requested By). When <Search History> is clicked, only OFAC search items matching the indicated criteria will appear in the top list.

The information displayed in the top list view includes the Date and Time of each search, where the search was processed (Source*), the number of Names returned by the search, the number of Suspects (matches) returned by the search, the username of the employee who performed the search (Requested By), and the actual name that was searched (Lookup Name). If zero (0) appears in the # Suspects column, there were no OFAC matches in that particular search.

If the # Suspects column displays a number 1 or higher, OFAC matches were found in that particular search. Select that history item in the top list to view further details about each suspect returned by the search in the bottom list view. The information displayed in the bottom list comes from OFAC files pertaining to each suspect name.

* The Source field/column indicates where the OFAC search was performed. If the results are from host searches, the Requested By information will be "OFAC Match Reporting," and you need to refer to the afterhours report (FPSDR338) for details. All other searches will be logged with the name of the person that performed the search. Possible values for the Source field are:

•ACH

•AP Check or ACH

•AP Vendor

•Bill Payer

•E-ACH

•International ACH

•Check Reconciliation

•Check Writer

•CIF Name

OFAC Enhancements

Enhancements to the OFAC system have been implemented to consolidate all U.S. security lists, such as:

•Specially Designated Nationals (SDN), published by OFAC. Persons in this list are blocked from doing financial transactions in the U.S.

•Foreign Sanctions Evaders (FSE), published in the consolidated sanctions list by the U.S. Treasury - OFAC. Persons in this list are blocked from doing financial transactions in the U.S.

•Sectoral Sanctions Identifications (SSI), in the consolidated list. Directives in the individual entries describe the prohibitions on dealing with the names in this list.

•Palestinian Legislative Council (NS-PLC), in the consolidated list. Those in this list are blocked from doing financial transactions in the U.S.

•List of Foreign Financial Institutions Subject to Part 561 (Part 561), in the consolidated list. Persons on this list may not be subject to sanctions after October 18, 2015. Institutions will need to refer to the U.S. Treasury website for specific sanction waivers.

•Non-SDN Iranian Sanctions Act (NS-ISA), in the consolidated list. Institutions will need to refer to the U.S. Treasury website for specific sanction waivers.

•Financial Crimes Enforcement Network (FinCEN 314a), a list published only to institutions and not accessible to GOLDPoint Systems. This list never blocks transactions; instead, institutions must report any activity within the last six months or any accounts on file within the last year for people on this list.

Additionally, we will also be using these new OFAC features to screen the following records:

•ACH records—Deposit accounts incoming ACH records (processes daily based on transactions)

•Accounts Payable Checks and ACH records (processes daily based on transactions)

•Accounts Payable Vendor List (processes with OFAC file changes)

•Bill Payment records (processes daily based on transactions)

•Check Reconciliation records (processes daily based on transactions)

•CIM GOLD Check Writer records—Teller system online OFAC check

•CIF records (processes with OFAC file changes)

•E-ACH records (processes daily based on transactions)

•International ACH records (processes daily based on transactions)

These features will affect Accounts Payable, loan servicing, deposits, and loan origination (GOLDTrak PC), as all names will be verified with the more robust OFAC search.