We are in the process of evaluating our OFAC compliance program. I have a few questions related to your OFAC screening process.
Do you screen authorized users (separate from the account owner) of credit cards against OFAC? Do you do this for both consumer and business credit cards?
Do you screen a non-member cashing an on-us check (e.g., teller, certified, consumer, business, etc.) against OFAC? If so, do you have a dollar amount threshold (e.g., any individual check or sum of checks greater than or equal to $1,000) at which you will screen the non-member against OFAC?
Also, do you screen a non-member cashing a savings bonds against OFAC? If so, do you have a dollar amount threshold (e.g., any individual bond or sum of bonds greater than or equal to $1,000) at which you will screen the non-member against OFAC?
Thanks for your help!
Dan Elston
BayPort Credit Union
