I work for a mortgage company that sells loans to banks and investors (used to work at a bank). Would a mortgage broker/correspondent have to verify their customers to OFAC or would this be just a bank requirement?

The OFAC rules apply to all financial transactions, no matter how you are organized, chartered, or regulated.

Compliance with OFAC is not exclusive to the financial/banking industry. All US persons and entities are prohibited from engaging in ANY transaction that violates OFAC sanctions.

From the OFAC website:
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Who must comply with OFAC regulations?

All U.S. persons must comply with OFAC regulations, including all U.S. citizens and permanent resident aliens regardless of where they are located, all persons and entities within the United States, all U.S. incorporated entities and their foreign branches. In the cases of certain programs, such as those regarding Cuba and North Korea, all foreign subsidiaries owned or controlled by U.S. companies also must comply. Certain programs also require foreign persons in possession of U.S. origin goods to comply. [09-10-02]
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Here is the link to US Treasury OFAC website that gives all the information you ever wanted to know...and then some!

US Treas OFAC Info

You originate the loan; you're the party making the decision to extend credit to the applicant. To be able to state to a loan purchaser or investor that you have not financed terrorism, you must have a due diligence process in place -- even if it's an old-fasioned manual procedure where you are printing and/or reviewing the OFAC list at the Treasury website. But you definately own this process.

Wow. So if I were to, let's say... sell a Babe Ruth baseball card to a buyer I became acquainted with via Ebay, and said buyer happenned to be an Al-Qaida member named explicitly on OFAC, I'm in violation?
If the answer is yes, has anyone ever gone after a retailler for violating OFAC?

Quote:

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...has anyone ever gone after a retailler for violating OFAC?

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WalMart for one. Depending how you define "retailer," Playboy Enterprises, for another. They like the high profile stuff. Heaven help Martha Stewart if anyone catches her with Cuban coffee.

Yep- check out the civil penalties (UPS got hit in MArch)'
http://www.treas.gov/offices/eotffc/ofac/civpen/penalties/index.html

I'm the 3rd anonymous poster in this thread....
Wow. So if I were to screw up badly enough, one OFAC fine could basically bankrupt me as an individual. Amazing.

Basically??? Some of the penalties for willful non-compliance are $5Million individually. That doesn't include jail time.

Bonnie's reference may not work literally, but the concept began with the "...Trading with the Enemies Act...," circa 1812.

From OFAC's website FAQ's:

How long has OFAC been around?

The Treasury Department has a long history of dealing with sanctions. Prior to the War of 1812, Secretary of the Treasury Gallatin administered sanctions imposed against Great Britain for the harassment of American sailors.