Topic: Selecting a Service Provider
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We outsource our credit card program. Although the cards have our bank logo on them and we provide the credit card applications, the applications are submitted directly to the vendor, and we have no access to account information. If a blocked person opens a credit card, are we liable for the OFAC violation? Are we liable for transactions that are processed through the credit cards?
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We do not believe that you would be held responsible for OFAC violations related to the credit card accounts issued by or transactions conducted through your third party credit card vendor, but it would be advisable to confirm this practice with your primary regulator. Of course, the scope of transactions covered by OFAC regulations is…