I recently received the following inquiry about OFAC & AML Compliance regarding RDC. What are your thoughts??...
I know that scanners should not be taken out of the country and FI’s should know their customers and that they are not doing any foreign items through RDC. But examiners are telling FIs that they have to OFAC each RDC deposit. Is that true?
...To which I responded the following...
What the examiners are saying is that the FI is responsible for all transactions, regardless of payment type (ACH, Wire, Check, etc.) and regardless of channel (Teller, RDC, ATM, Mobile, etc.), and these transactions are subject to OFAC and AML requirements. All deposits have always been subject to this, even before RDC. This should not be anything new. What might be new is the fact that it is now easier to monitor, report and comply than ever before.
What are your thoughts??