OFAC Compliance For International Wire Transfers

[Bryan Hancock]

I was wondering if any of our lending wizards on the forums had some recommendations for OFAC compliance for accepting international wire transfers.  We're looking to find a good lender that has robust policies for this and preferably has software for comparisons that is updated in real time or close to real time.  

Other concerns are Patriot Act and other laws relevant to accepting foreign funds.  Securities laws are a separate item that we're working with attorneys.  The main thing I need is a good referral to a lender that does this all the time and is in the business of moving money internationally.  Someone that can indemnify us for non-compliance when we rely on their policies/procedures would be the best.

Any thoughts?

[Hattie Dizmond]

@Bryan Hancock 

All banks are covered by the same requirements.  However, the big banks, particularly those with strong international presences have the most robust controls and most automation around those controls.

JP Morgan Chase & CitiBank probably do the most international lending, including highly complex syndicated lending in the international space.  Both banks have robust controls around OFAC requirements, including real-time "kick-out" of transfers to &/or from companies on the black list &/or wires originating from or going to countries on the black list.

You will be safe with either of those banks.  I would imagine Wells & BofA have the same controls in place.  However, I have personal knowledge of the Commercial Loan & Wire areas of both JPMC & Citi.