Sanctions Screening

List names, match rules, and a form for a documented screening.

Sanctions Screening

OFAC Compliance

Quick answer. OFAC compliance means a repeatable way to screen, escalate possible matches, and keep the list file current. One ad-hoc search is a sample, not a program. Sanctions screening means checking names against current sanctions lists and writing down the result. Software helps only if it shows the list date. OFAC’s 50 percent rule can block an entity that is not itself named, based on ownership.

Official office

Office of Foreign Assets Control

Open the official search

Steps

  1. Show the list version

    A tool that cannot display the SDN file date is not ready.

  2. Escalate possible matches

    Someone named in the policy compares identifiers. “Dismiss” without a note is not a file.

  3. Ask the ownership question separately

    50 percent aggregation is not on the SDN search page.

  4. Keep OFAC compliance as a repeatable process

    One manual search is a sample. A program has an owner and a refresh cycle.

OFAC compliance is a program, not a single search

Write down who may clear a weak match and what identifier they must compare. Keep the search date and the list version.

OFAC’s own search page says use of the tool does not limit liability for acts taken in reliance on it. The program is still yours.

A program, not a single green check

False positives are similar names. Clear them by comparing date of birth, address, and ID, and keep that comparison. Lowering the match threshold to empty the queue hides names. OFAC will not choose the threshold.

The 50 percent rule is an ownership test. A clear SDN search on the company name does not answer it. You need ownership facts. This site will not give a legal opinion on a close case. We can still pull the public entity record and the OFAC name results.

Common mistakes

  • Trusting a score with no list date.
  • Deleting weak matches with no write-up.
  • Assuming a clear name search solves ownership.
  • Treating screening software as a government certificate.

Questions

What is sanctions screening software?

A tool that loads official lists and scores names. It still needs a person and a current file.

What is a false positive?

A possible match that identifiers show is not the listed person. Document the comparison.

What is the 50 percent rule?

OFAC treats an entity owned 50 percent or more in the aggregate by blocked persons as blocked, even if the entity is not on the SDN list. Get counsel for a real transaction.

Sources reviewed