In IRS Notice 2005-5, a footnote indicates that the CIP compliance pursuant to the Patriot Act is not required at the time an IRA is established when a trustee forces a participant out of a plan. I do not see a similar note regarding OFAC compliance. Does anyone know if the OFAC screening is necessary or if this can also be deferred until the individual decides to claim the funds? It would make sense that this is deferred too, but I can't find information to that effect and know better to assume things work the way I think they should.

No citation, but I seem to recollect that OFAC screening would not apply because the definition of 'account' excludes those set up by an ERISA plan and that an ERISA plan setting up an automatic rollover IRA would be so excluded.

MSN

What is it that makes OFAC screening a concern when dealing with a 401(k) rollover ? I assume that the rollover is from a known or easily verified entity to a previously known entity with whom you have an existing relationship.

I seem to recollect that OFAC screening would not apply because the definition of 'account' excludes those set up by an ERISA plan and that an ERISA plan setting up an automatic rollover IRA would be so excluded.

Wow, that reads so much better when not prefaced with "No citation, but...".