4th Quarter 2022 Contents:

Case #1 – You don’t have to … but heaven help you if you don’t.  There is nothing in federal law that requires banks to do OFAC scans after each SDN update. But those that don’t are being harshly criticized by their regulators.

Case #2 – NSF refund update.  There’s a lot of speculation and rumor about what’s going on … and I guess we’re adding to it. But we’re trying our best to offer  interesting insights.