Who is responsible for OFAC compliance?
All depository financial institutions, whether originating or receiving, are responsible for OFAC compliance. Likewise, OFAC compliance applies to third-party service providers, including processors and correspondent/respondent banks. Although a financial institution might contract with a third-party provider to do the actual OFAC review of the transactions, OFAC rules clearly indicate that a financial institution cannot contract away its liability for OFAC compliance.
