Frequently Asked Questions

88 … OFAC cannot give specific advice on how to design an automated system for downloading its sanctions list data. Many institutions solve this problem by setting up a scheduled download of the SDN List and other sanctions lists . These firms conduct their own risk assessments and decide how often… Read more

89 … The SDN list and OFAC's non-SDN Consolidated lists are comprehensive. Database administrators can overwrite any old data in their systems with the latest versions of the list's data files, thus ensuring that their database is current … I am a database administrator at a financial institution… Read more

90 … No. OFAC records changes to the SDN and other sanctions lists in human-readable form in the recent actions section of its website. An archive of changes files found on this page . Database administrators interested in refreshing their databases with new SDN and other sanctions list data should… Read more

22 … OFAC has long maintained such a list. The file is available on OFAC's SDN Page under the link " SDN List Sorted by Country ."  It is important to understand that many SDN individuals and entities may operate in countries other than those in which they are based. The relevant regulations… Read more

105 … OFAC has rigorous quality control procedures in place to ensure that all sanctions list data are current and accurate when they are released (including all of its human-readable list formats [in PDF and text]). All of the sanctions list information is downloaded and checked by OFAC personnel… Read more

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

53 … In those programs with blocking provisions, OFAC's regulations block all "property" in which a target has an interest. The term "property" is very broadly defined, including present, future or contingent interests. In the case of a wire transfer, the bank will be holding blocked property upon… Read more