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

44 … There is no minimum or maximum amount subject to the regulations. … Is there a dollar limit on which transactions are subject to OFAC regulations? …

45 … Every transaction that a U.S. financial institution engages in is subject to OFAC regulations. If a bank knows or has reason to know that a target is party to a transaction, the bank's processing of the transaction would be unlawful. … Does my bank need to check the OFAC list when selling… Read more

46 … If you have confirmed with OFAC that you have a "good hit" on the SDN list or one of OFAC's other sanctions lists , there is no reason not to explain that to the customer. The customer can contact OFAC directly for further information. … If a loan meets underwriting standards but is a true "… Read more

47 … Donations to charitable institutions must be handled as any other financial transaction. The donating bank or institution should crosscheck the recipient names against OFAC's sanctions lists and assure that the donations are in compliance with OFAC sanctions programs . … Through corporate… Read more