OFAC Settlement Highlights Need for Continuous Screening

On July 21, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) released a "finding of violation" against MidFirst Bank. The violation was due to MidFirst maintaining accounts and processing payments for two individuals on OFAC's Specially Designated Nationals and Blocked Persons List (the SDN List).  This occurred because MidFirst's screening vendor "only screened MidFirst’s entire existing customer base once a month." Daily screening was only conducted for new and updated customers.  When a customer was added to the SDN list, transactions continued to go through for two weeks before the customer's SDN listing was recognized.

Since the SDN List and other sanctions lists are subject to daily change, continuous screening is a must-have. ECScreening downloads and screens Recurring Searches against updated sanctions lists every 24 hours.  Knowing about potential sanctions issues as soon as possible is a key element in compliance programs in order to prevent ongoing business with sanctioned parties.