We are a risk consulting company and we have a client who has a customer who had a typo on his wire that caused a bank to return it because the name was like a name on the OFAC (Office of Foreign Assets Control) list. What should the customer do to assure that he will not be put on a watch list or have any further problems from this typo?
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Assuming that your client has discussed the reason for the error, and that the wire has subsequently been sent successfully, you should ask him to verify all information in wire instructions as keyed by the bank. It is reasonable that the bank will realize that the problem was caused by its error and will not subject your customer's account to any unusual scrutiny based on the erroneous OFAC match. However, you should know that banks watch wire transfer activity in particular quite closely, because of the special risks undertaken by banks with regard to wires. If a customer's wire activity is congruent with the bank's understanding of the customer's normal business transactions, we don't think that your customer's bank will have any problems with those transfers.
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Assuming that your client has discussed the reason for the error, and that the wire has subsequently been sent successfully, you should ask him to verify all information in wire instructions as keyed by the bank. It is reasonable that the bank will realize that the problem was caused by its error and will not subject your customer's account to any unusual scrutiny based on the erroneous OFAC match. However, you should know that banks watch wire transfer activity in particular quite closely, because of the special risks undertaken by banks with regard to wires. If a customer's wire activity is congruent with the bank's understanding of the customer's normal business transactions, we don't think that your customer's bank will have any problems with those transfers.
