Frequently Asked Questions

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

1 … The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions against targeted foreign jurisdictions and regimes, as well as individuals and entities engaging in harmful activity, such as terrorists, international narcotics… Read more

3 … Each OFAC sanctions program is based on different foreign policy and national security goals, so the prohibitions imposed may vary between programs. Many sanctions programs require blocking the property and interests in property of specific individuals and entities and prohibit dealing in such… Read more

4 … Yes. There may be exceptions to sanctions prohibitions. Exceptions may take the form of authorizations, such as general licenses and specific licenses, or exemptions. OFAC issues general licenses in most of its sanctions programs to authorize certain transactions that would otherwise be… Read more

6 … References to relevant statutes, executive orders, regulations, guidance, general licenses, and sanctions actions for each sanctions program may be found in the Sanctions Programs and Country Information page on OFAC’s website. The OFAC Legal Library page on OFAC’s website also contains links… Read more

7 … OFAC issues general licenses to authorize certain transactions that would otherwise be prohibited pursuant to a particular sanctions program. These general licenses are self-executing, meaning they allow persons to engage in certain transactions involving the United States or U.S. persons… Read more