Regulations

Are the Publicly Traded companies OFAC compliant or is it necessary to do a manual OFAC check on them? 

Since the OFAC lists change frequently, we (Vendor Management) check OFAC for all new vendors before the contract is signed and going forward, Accounts Payable checks OFAC before any/every payment is made. 

I'd be interested in changes, if any, others are considering in light of the June 2023 interagency guidance (FIL-29-2023). 

"any" and the OFAC and FinCEN definitions around ownership are not the same. 

Do you plan to rely on "or" vs. "and" ?

etc.

From FIL-29-2023:

Legal and Regulatory Compliance {2.b.(2) } includes scanning owners of third-party in the OFAC scans.
"(2) determining whether the third party itself or any owners are subject to sanctions by the Office of Foreign Assets Control"

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Greg Schmeisser
Dir. Corp. Contracts & Procurement
First Merchants bank
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