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The monthly vendor OFAC scrub for accounts payable, with a CSV template

Published . Sources checked on that date.

To scrub your vendor file for OFAC, export every active vendor's legal name, other names, country and tax ID, screen the whole file against OFAC's SDN and Consolidated lists, clear each hit with a written reason, and file the dated results in the audit binder. OFAC does not set a frequency: it says the frequency of scanning must be guided by your own policies and procedures (OFAC FAQ 28). Monthly, plus every new vendor before its first payment, is a defensible schedule to write into that policy.

Use the files, not the search box

For a whole vendor file, work from OFAC's downloadable lists. OFAC publishes the SDN list as a CSV that opens in a spreadsheet (OFAC FAQ 80), and its Sanctions List Service offers SDN and Consolidated list downloads (Sanctions List Service). The SDN and Consolidated files are complete each time, so you can overwrite last month's copy with the new one (OFAC FAQ 89).

OFAC's free Sanctions List Search is meant for individual users and should not be driven by automated systems running searches continually (OFAC FAQ 287). It is fine for checking one new vendor by hand.

A CSV layout for the results

One row per vendor per scrub. Keep the file for each month; do not overwrite it.

vendor_id,legal_name,other_names,country,tax_id,screened_at,sdn_list_date,cons_list_date,result,candidate,reviewer,decision,reason
V-1001,Example Vendor One LLC,Example One,US,12-3456789,2026-10-07T14:02Z,2026-10-05,2026-09-14,no candidate,,,,
V-1002,Example Vendor Two Ltd,,AE,,2026-10-07T14:02Z,2026-10-05,2026-09-14,candidate,<list entry name and number>,J. Clerk,cleared,"Different country and registration number from the listed entry"

What each column is for:

  • sdn_list_date, cons_list_date: the publication date of the list version you screened against. This is what shows the auditor which list you were checking.
  • result: "no candidate" or "candidate". A candidate is not a finding; it is a name to review.
  • reviewer, decision, reason: the human decision on each candidate, in a sentence someone else can follow.

The example rows show the shape only. Vendor names, numbers and dates are placeholders.

Clearing a vendor hit

Compare the full list entry with what is in the vendor master: legal name, country, address, registration or tax number. OFAC's guidance notes that several businesses can share an address, so an address match alone may not be enough (OFAC FAQ 5). Our false positive guide has a reason template.

Also check ownership on vendors that matter. Any entity owned 50 percent or more, in the aggregate, by blocked persons is blocked even if it is on no list (OFAC FAQ 91).

When a vendor is a true match

Hold the payment. If the vendor is on the SDN list, its property must be blocked: OFAC's guidance says blocked funds go into a segregated, interest-bearing account at a federally insured U.S. financial institution (OFAC FAQ 5). Report the blocking within 10 business days, and file an annual report of blocked property held as of June 30 by September 30 (31 CFR 501.603). A rejected payment with nothing to block is also reported within 10 business days (31 CFR 501.604).

What goes in the audit binder

  • this month's results file and the list publication dates it used
  • the written reason for every cleared candidate
  • the policy that sets the schedule

OFAC requires records of each transaction subject to its rules for at least 10 years (31 CFR 501.601).

Check a new vendor now

Run a free OFAC check on a new vendor before the first payment, against the current SDN and Consolidated lists. This is screening data, not legal advice.