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How to run an OFAC check and keep the proof

Published . Sources checked on that date.

To run an OFAC check, search the person's or company's name against OFAC's Specially Designated Nationals (SDN) list and its Consolidated (non-SDN) list, compare any hit with the full list entry, decide, and write down what you checked, when, against which list version, and why you cleared or stopped the deal. OFAC's free Sanctions List Search covers both lists (OFAC FAQ 369). OFAC asks for complete records of how you investigated a potential match (OFAC FAQ 5).

Step 1: Get the identifiers before you search

A name alone is a weak check. Before you run it, collect what you will need to clear a hit: full legal name and any other names used, date of birth, nationality, address, and an ID number for a person; legal name, country, address and registration number for a company. OFAC's own guidance on assessing a match compares exactly these details (OFAC FAQ 5).

Step 2: Search both lists

Search the SDN list and the Consolidated list. Sanctions List Search returns potential matches from both (OFAC FAQ 369). Only its name field uses fuzzy matching (OFAC FAQ 252), and OFAC does not recommend a match threshold: each user sets one from their own risk assessment (OFAC FAQ 250).

Two limits to know:

  • The tool shows only the current lists. Names that have been removed do not appear in it (OFAC FAQ 467).
  • A company can be blocked without being listed. Any entity owned 50 percent or more, in the aggregate, by blocked persons is blocked whether or not it appears on the SDN list (OFAC FAQ 91). A name search will not find it. See the 50 percent rule with worked examples.

Step 3: Review any hit against the full entry

Most hits are not the person in front of you. OFAC says many potential matches are false positives and sets out how to check them: open the complete list entry and compare date of birth, nationality, ID numbers and address with what you collected in step 1 (OFAC FAQ 5). If only the first or last name matches and the other details differ, you may not have a valid match. If several details match, such as name and date of birth, OFAC's guidance treats it as a likely match to be worked through your procedures before anything proceeds.

OFAC does not confirm or rule out matches for you. It expects a risk-based decision made under your own procedures (OFAC FAQ 5). The detailed method is in how to clear an OFAC false positive.

Step 4: Keep the proof

The record is what you show a lender, an underwriter or an auditor later. For every check, keep:

  • the name and identifiers you searched
  • the date and time of the search
  • which lists you searched and the publication date of each
  • the result: no candidate, or each candidate with your reasoning
  • who reviewed it and what they decided

OFAC can demand complete information about any transaction subject to its rules, including the documents behind it (31 CFR 501.602). Records of each such transaction must be kept for at least 10 years (31 CFR 501.601). A screenshot with no date and no list version proves little; a dated record that names the list publication proves what you could have known on the day.

If the hit is real

Do not proceed. If the party is on the SDN list, their property must be blocked; if the deal is prohibited but nothing is blockable, it must be rejected (OFAC FAQ 5). Either way, report it to OFAC within 10 business days (31 CFR 501.603, 31 CFR 501.604).

Why the record matters

OFAC generally enforces on a strict liability standard: a U.S. person can be held civilly liable even without knowing or having reason to know of the violation (OFAC guidance, October 2021, p. 6). The civil penalty under IEEPA can reach the greater of $377,700 or twice the value of the transaction (31 CFR 505.401). OFAC considers the existence and adequacy of a compliance program when it decides a penalty (31 CFR Part 501, Appendix A). A dated record of each check is the evidence that your program ran.

Run one now

Run a free OFAC check against the current SDN and Consolidated lists. Each result shows which name or alias matched and the publication date of the lists it was checked against. This is screening data, not legal advice.