Which entity verifies the originator's compliance with OFAC?

• A. Documentation of Screening
• B. Check Payees
• C. Originating Depository Financial Institution (ODFI)
• D. OFAC Compliance

Answer: (C)

OFAC screening happens at the point the payment is originated. The Originating Depository Financial Institution (ODFI) is the party that checks the originator against the OFAC sanctions list before transmitting the payment through the network. This institution bears the responsibility to ensure the originator is not sanctioned and to block or reject the transfer if there’s a match. While documentation of screening and an OFAC compliance program support these controls, the actual verification of the originator’s OFAC status is performed by the ODFI. The other options either refer to supporting processes (documentation of screening), the recipient’s details (check payees), or the bank-wide program (OFAC compliance) but not the entity that performs the live verification for the originator in the transaction flow.