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.)? 

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.)? 

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.)? 

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.

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.)? 

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.

Original Message:
Sent: 02-09-2023 05:40 PM
From: Brenton Smith
Subject: OFAC Ongoing Checks

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.)?