If a gateway operator is going to perform OFAC due diligence on inbound IATs, what additional responsibilities does an RDFI have surrounding OFAC compliance?
Ultimately, the receiving financial institution bears all responsibility for OFAC compliance. Although the gateway operator will perform inbound screening on inbound IAT items and populate the necessary fields, the receiving financial institution is still required to perform the necessary due diligence on IAT items in order to properly comply with OFAC obligations.
Related Questions
- It seems that inbound IATs with secondary SECs will require additional information in the Remittance Information addenda that will need to be provided on the statements. Is that correct?
- If a gateway operator is going to perform OFAC due diligence on inbound IATs, what additional responsibilities does an RDFI have surrounding OFAC compliance?
- How many additional workload units do I collect when going to the Operating Room to perform an x-ray?
