Frequently Asked Questions

122 … A "weak AKA" is a term for a relatively broad or generic alias that may generate a large volume of false hits when such names are run through a computer-based screening system.  OFAC includes these AKAs because, based on information available to it, the sanctions targets refer to themselves,… Read more

123 … Weak AKAs appear differently depending on which file format of the sanctions list is being utilized. In the TXT and PDF versions of the Specially Designated Nationals (SDN) or other sanctions lists , weak AKAs are encapsulated in double-quotes within the AKA listing: ALLANE, Hacene (a.k.a.… Read more

124 … OFAC’s regulations do not explicitly require any specific screening regime. Financial institutions and others must make screening choices based on their circumstances and compliance approach. As a general matter, though, OFAC does not expect that persons will screen for weak AKAs, but expects… Read more

125 … A person who processes an unauthorized transaction involving a sanctions list entry has violated U.S. law and may be subject to an enforcement action. Generally speaking, however, if (i) the only sanctions reference in the transaction is a weak AKA, (ii) the person involved in the processing… Read more

40 … This depends on the program. If you have a payment involving an embassy in a targeted country, please contact OFAC Compliance's hotline for directions. … If my financial institution receives a wire going to an embassy in a sanctioned country, can we process the …

43 … There is no legal or regulatory requirement to use software or to scan. There is a requirement, however, not to violate the law by doing business with a target or failing to block property. OFAC realizes that financial institutions use software that does not always provide an instantaneous… Read more

372 … On November 28, 2017, OFAC issued General License 1B , which continues to authorize certain transactions involving derivative products that would otherwise be prohibited pursuant to Directives 1, 2, or 3. General License 1B replaced and superseded General License No. 1A, dated September 12,… Read more

373 … Yes, these prohibitions apply to the named persons, their property, and their interests in property, which includes entities owned 50 percent or more by one or more persons identified as subject to the Directives. On October 31, 2017, OFAC amended and reissued Directive 4 in accordance with… Read more

550 … When OFAC uses the term "SSI entity" in these FAQs or in other guidance, it is referring to an entity subject to the Directive(s) at issue in a particular FAQ or piece of guidance. … When OFAC references a prohibition involving an “SSI entity” in these FAQs or in other guidance, what does… Read more

374 … If a U.S. person is in possession of a Kalashnikov Concern product that was bought and fully paid for prior to the date of designation (i.e., no payment remains due to Kalashnikov Concern), then that product is not blocked and OFAC sanctions would not prohibit the U.S. person from keeping or… Read more