Frequently Asked Questions

90 … Yes, OFAC offers a delta file as part of its Sanctions List Service (SLS) .  While this delta file format is used by OFAC to update its sanctions lists on SLS, members of the public may use this file as well.  OFAC also records changes to the SDN list and other sanctions lists in human-… 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 prohibit… 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

244 … The ITSR include several general licenses that newly authorize, or continue to authorize, activities that are otherwise prohibited by the regulations. Categories of activities affected by these changes include, among other things, visa-related transactions, journalistic activities in Iran,… Read more

245 … The Statement of Licensing Procedure reflects procedures established pursuant to section 413 of the Iran Threat Reduction and Syria Human Rights Act (the TRA). These procedures stipulate that, as of the effective date of the TRA, license determinations for complete requests for authorization… Read more

254 … Pursuant to the restrictions already in place under the National Defense Authorization Act (NDAA), foreign financial institutions (“FFIs”) face restrictions on, or loss of, correspondent and payable-through account access in the United States if they knowingly engage in significant financial… Read more