OFAC compliance

I work for an insurance company; we are subject to OFAC and the following describes this compliance requirement:
"OFAC stands for Office of Foreign Assets Control, which is part of the US Department of Treasury. OFAC administers and enforces sanctions policy based on Presidential declaration of “national emergency,” under nine statutes. U.S. underwriters, brokers, agents, primary insurers and reinsurers are prohibited from engaging in transactions with anyone appearing on the Specially Designated Nationals and Blocked Persons List (SDN list), as well as governmental entities and officials of Libya, Sudan or Cuba and Cuban companies or citizens unless licensed by OFAC. Criminal violations can result in corporate and personal fines of up to $1 million and 12 years in jail. Civil penalties may also be imposed. "

As part of our corporate due diligence, we must check new hire candidates against this list of individuals to ensure that they are not on the list. We did our first check today (we are planning to make an offer on a position), so it's the first we've had a chance to look at the list. You basically search by full name and if it matches at all, it will produce the names it matched against. It does not have SSN, but does list DOB. I'm now wondering if we should create a separate DOB request form for applicants, telling them we need it for OFAC and it will only be used for this verification purpose. We do not currently collect DOB on any forms, except for health care insurance forms.

Anyone else have to deal with this? Yeesh ..xflash how many more background checks can we do?!


  • 3 Comments sorted by Votes Date Added
  • Make the offer and make it contingent upon the results of the background check. If something is unacceptable in the background investigation, you came terminate the employee at that time. At the facility I work at, if something in an employee’s background prevents him/her from obtaining or causesthem to loose their security clearance, they are immediately released from employment.
  • Do you also do a CORI check? If so, the SSN and DOB are on the form. We have all candidates to whom an offer has been extended complete an acknowledgment of conditional employment, which clearly states that if the CORI or other checks we are required to complete (OIG and Nurses' Registry)are unsatisfactory, the offer of employment will be withdrawn.
  • No, we don't do a CORI check - not sure what that is?

    And to the other poster, thanks for the recommendation but I believe we need to check the status on this list prior to hiring, just as we have to do on any vendors and policyholders, prior to doing business with them.
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