US
Patriot Act and O.F.A.C. Regulation
US Department
of Treasury, The Office of Foreign Asset Control (OFAC) and Securities and
Exchange Commission (SEC) have mandated a
requirement for financial firms to comply to Section 326 of the USA Patriot Act.
The deadline to comply with the law is set for October 1st, 2003.
The
new regulation requires that financial institutions develop a Customer
Identification Program (CIP) that implements reasonable procedures which:
-
Collect identifying information about customers opening an account
or existing accounts
-
Verify the validity of
those customers - (verify what they say they
are)
-
Maintain records of the information used to verify their identity
-
Determine whether the customers appears on any list of suspected
terrorists or organizations as listed by OFAC
|
Collect
Customer Info
|
Verify
Validity
|
Maintain
Records / Notes
|
SDN
Verification
|
|
Develop
Procedures
to collect data
|
Develop
procedures to verify customer data
Develop
procedures to utilize alternate methods to verify customer identity
|
Maintain
records including method used to obtain data
|
Develop
procedures to check customers against suspected terrorist List and
organizations (as per OFAC SDN List). Also develop
procedures to freeze assets if there is an OFAC-hit.
|
How
do firms comply to US Patriot Act?
By collecting and verifying customer data
in a proper form, the firms can adopt additional work-flow procedures to
comply with the US Patriot Act. Here is our
detailed analysis in regards to the data that firms should gather
and verify.
Most
of the financial institutions have adopted several platforms to store and
maintain their customer data. Many firms have adopted a Straight
Through Processing (STP) solution and workflow methods for customer account
maintenance.
In
order to comply with the section 326 of the US Patriot Act, the
financial/brokerage firms need to collect required customer data for
verification. These firms may already have data but may
not be available in the form where they can verify. Therefore, data
cleansing/profiling OR data enrichment tasks need to be performed to begin
with. Firms also need to go over through a change in their workflow methods
to incorporate regulatory requirements. This is a huge task specially
meeting with the compliance deadline of October 1st, 2003.
How can
eOutsourceIT help?
eOutsourceIT
is ready to help you to collect required data, clean data and set up
workflow procedures. Our approach is very simple and structured to achieve your
goal.
-
eOutsourceIT
will work with you to identify your firm's immediate requirement
(e.g. check against OFAC list and comply with the requirements without
changing existing workflow OR change the workflow right away and establish
procedures)
-
Using our
off-shore presence, we will tailor your requirements to
develop proper workflow procedures using secure 'VPN-based'
connectivity.
-
We can leverage our Business Process Outsourcing stream to manually
verify and check your customer data. This includes the following checks:
§
Verification
of the Documents
§
SSN
Validity using our government published data
§
SSN
and Personal data Verification
using your existing tools
§
State/Zip
validation
§
State/ZIP/Area
code verification
§
Country/Phone
number verification
§
Alternate
Method Verification
using your existing procedures
§
Check
against OFAC SDN List and Generate Report
-
eOutsourceIT
also provides services to clean and enrich your data (e.g. Firms
may maintain only mailing address lines whereas above checks require
individual fields to be verified)
-
If you already have adopted third-party tools for alternate method
verification, not a problem. We will work with you and educate our off-shore
team, provided our team has access to these tools and
applications involved.
e-OFAC-Check
- a service from eOutsourceIT
Our service includes,
-
SSN Validation
(Identify incorrect formatted SSN, not-issued SSN etc.)
-
Enrich data by
providing state code where SSN was issued
-
OFAC-SDN List check
for last name of a customer
-
OFAC-SDN List check
for possible aliases of the last name of a customer
-
Match Report
including direct and indirect matches
-
Overall Exception
Report
-
Hands-on Research for
OFAC-hit Account Holders
-
Create a Blocked
Properties Report for OFAC Submission
In order to provide the
best services, we have developed few procedures to,
-
download OFAC-SDN
list every night even if there is NO change in the list
-
audit trail of
OFAC-SDN changes
-
download of
government published allocated SSN data (last issued SSN by state)
While
working with your customer data, we never compromise. We take every single
step to protect confidentiality of your data. Our team members work in a
non-disclosure agreement. Refer to our Privacy
Policy for more details.
For more information, please email us at info@eOutsourceIT.com
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