As stated in its public announcement of June 13, 2012, OFAC has made a number of changes to its internal Specially Designated Nationals (SDN) list production system. Among these changes, item 5 in the June 13, 2012 announcement stated that care of addresses would be replaced by a "linked to" statement. Because there is no limit on the number of linked to names that can be added to an SDN record and because linked to names are being stored in the remarks field of OFAC's legacy fixed-width and delimited files, there is a potential for the remarks field to exceed the stated 1000 character limit of that field. At present, OFAC is aware of two records that exceed the prescribed 1000 character limit. They are record UIDs 4176 and 12300. OFAC was aware that the logic in our list production system was allowing the delimited legacy files to exceed the 1000 character specification, while the remarks field in the fixed-width data files was being truncated at the prescribed limit. OFAC has made a change to its system to make the truncation rule consistent. In light of this truncation rule, OFAC wishes to ensure that users of the legacy delimited and fixed width data files have access to all SDN data. We have therefore created "spillover" files that will be released with the next SDN update after this announcement. These spillover files will capture any data that were truncated by the 1000 character rule. Users of OFAC's legacy files are advised to review the data in the spillover files and make business decisions about what data to include in their screening systems and what data to ignore. The spillover files will be presented in a data file format similar to the legacy flat files so it will be possible to automate the consumption of these data. Given the fact that the spillover files are designed to catch the potentially unlimited number of identifiers that can now be added to the remarks field for each SDN, there will be no upper row length for the data in the spillover files.
The names of the spillover files are as follows:
sdn_comments.csv
sdn_comments.pip
sdn_comments.ff
sdn_comments.del
These files will be included in the SDN archive files and will be listed separately on the OFAC website's SDN page. They will also be listed separately in the library/fac_dlim and /fac_delim folders of OFAC's FTP sites.