Policy, Program and Procedures

Our company performs OFAC checks before contracting with all third parties, but are there best practices or regulatory guidance that contemplates how often third parties should be screened for OFAC on an ongoing basis?  For example, annually, or prior to any new contracts being executed, or in conjunction with the review schedule that the third party falls under (annually, biennially, etc.)? 

I have experienced some financial services industries completing the OFAC process each time there is a transfer of money to the vendor/entity. That seems like it would be on the extreme end however. 

In our organization, Vendor Management performs an OFAC verification any time an agreement, amendment, SOW, etc. comes through for Legal review.  As part of the Accounts Payable process, an OFAC verification is performed whenever a payment is made.  

We were running them monthly for all vendors in our VM platform.  Now that it can be automated in the platform we are running it weekly.  Additionally, our accounting team sends a listing of vendors paid in the month to our BSA team for them to run in their OFAC reports, this captures any vendors not currently in our VM platform.

Do you ever get a match?!!