The OFAC laws and regulations promote national and international security by requiring asset freezing of: oppressive governments, international terrorists, narcotic traffickers, and other specially designated persons.

iFreeze from Metavante Banking Solutions can help protect your financial institution from doing business with countries that are under sanctions or specially designated nationals. iFreeze will match your financial institution's database of customers to the Treasuries' list of people and nations with whom conducting transactions is prohibited and will scan both new and existing accounts each day, producing a possible match list each night.

If an account serviced by your financial institution is flagged by iFreeze you are required to report all blockings to OFAC within ten days of occurrence. If your bank does not block and report a transfer and another bank does, then your bank is in non-compliance. A bank in non-compliance may be subjecting itself to adverse publicity, fines, and even criminal penalties (if violations are other than inadvertent).

Every type of financial account and transaction should be reviewed for OFAC compliance including, without limitation, the following:

• Deposit accounts
• Loans
• Lines of credit
• Safety deposit boxes
• Wire transfers
• ACH transfers
• Currency exchanges
• Depositing or cashing checks
• Purchase of money order or cashiers checks
• Loan payments
• Guarantors and collateral owners
• Trust accounts
• Credit Cards

In addition, the names of all parties to a transaction should be checked against the list of names of individuals, entities, geographical locations or countries that have been identified by OFAC. This includes, but is not limited to the following:

• Beneficiaries
• Collateral Owners
• Guarantors/Cosigners
• Receiving Parties
• Sending Parties

If the blocked transaction is a deposit, your financial institution is to accept the funds and immediately place the funds in a blocked account so they cannot be withdrawn.

If the transaction is a transfer of funds (by, through, or to your financial institution) you should accept the funds, but instead of transferring them, put them into a blocked account so that no funds can be withdrawn.

In general, your customer should be advised immediately of the blocking of the account or funds.

It is also important to know that OFAC requires that an annual report of all property blocked as of June 30 be submitted by September 30th of each year. In addition, OFAC requires the retention of all reports blocked or rejected transaction records for five years.

Metavante Banking Solutions understands that it is often difficult to balance the demands of Federal and State regulatory organizations with limitations on time, resources, and manpower imposed by bank management. That’s why iFreeze works continuously to ensure that you are only conducting business with legitimate individuals, businesses and organizations, making you aware of a potentially inappropriate transaction before it becomes a problem.