Sanctions screening software for a small business: a buyer's checklist
Good sanctions screening software for a small business covers OFAC's SDN and Consolidated lists (plus trade.gov's Consolidated Screening List if you export), shows the publication date of every list it screened, explains each match score, searches aliases, takes a batch file, re-screens saved names when a list changes, keeps a dated record of every check, offers an API, and publishes its price. If you only run a few checks a month, OFAC's free Sanctions List Search may be enough (OFAC FAQ 287).
The checklist
1. Lists covered
Start with what you are required to screen. Every US business must avoid dealing with blocked persons on OFAC's lists; the SDN and Consolidated lists are published by OFAC's Sanctions List Service (Sanctions List Service). Exporters also screen the Commerce and State lists, which trade.gov combines with OFAC's into the Consolidated Screening List (trade.gov CSL). Ask the vendor for the exact list names, not "thousands of lists".
2. Freshness you can see
OFAC publishes changes to its lists as recent actions, on no fixed schedule (OFAC recent actions). The tool should show, on every result, the publication date of the list version it used. A result without a list date cannot prove what you checked.
3. Fuzzy matching with an explained score
Names are misspelled, transliterated and reordered. OFAC's own search scores similarity using a phonetic algorithm and a character-similarity algorithm (OFAC FAQ 247). Whatever the tool uses, it should tell you why a candidate scored as it did: which name or alias matched and on which part.
4. Aliases
Many listed parties trade under other names. A check that only compares against the primary name misses them. Confirm the tool searches every alias on the list entry.
5. Batch upload
Accounts payable and onboarding teams screen whole files, not one name at a time. Look for CSV upload of your customer or vendor file, with one result per row. Our monthly vendor scrub guide has a layout for the results.
6. Monitoring on list change
A vendor that was clear last month can be designated today. OFAC leaves screening frequency to your own policy (OFAC FAQ 28), so the tool should make the policy easy to keep: re-screen saved names on each new publication and alert you only when something changes. See how often to re-screen.
7. An audit record for every check
The record should hold the name screened, the time, the list versions, every candidate with its score, and the decision with a written reason. OFAC requires records of transactions subject to its rules for at least 10 years (31 CFR 501.601), so ask how long the vendor keeps yours and whether you can export it.
8. Clearing false positives
A common name will produce candidates that are not your party. The tool should let you record why, so the next check of the same customer does not start from zero. See how to clear an OFAC false positive.
9. An API
If screening belongs inside your signup, checkout or vendor onboarding, you need an API that returns the same record as the web app. See screening with the OFAC API.
10. Published pricing and no sales call
A small business should be able to see the price, start, and cancel without a demo. Compare published plans on monitored names and records, not only on search counts. Our dated comparison lists several.
When the free tools are enough
- A few checks a month. OFAC's Sanctions List Search is free and searches the SDN and Consolidated lists. OFAC says it is intended for individual users and should not be run by automated systems continually (OFAC FAQ 287). It keeps no record, so save the result with the date yourself.
- Occasional export checks. trade.gov offers a search engine, downloadable files and an API for the Consolidated Screening List. trade.gov notes that a possible match calls for additional due diligence and a check of the official publication of the restriction before you proceed (trade.gov CSL).
Paying starts to make sense when the checks are frequent, when you need the record for an auditor, lender or underwriter, or when you have a list of customers or vendors that must stay clean between checks.
What the software does not do for you
Screening is one part of a program. OFAC's framework names five components: management commitment, risk assessment, internal controls, testing and auditing, and training (OFAC framework). A tool supports the internal controls and produces evidence for testing. The policy, the training and the decisions are still yours; our compliance program template covers them.
Try the check first
This is screening data, not legal advice. Run a free check against the SDN and Consolidated lists and look at the score explanation and list dates before you decide.