You are screening your vendors for sanctions, right? You check the new vendors going into your master file against the Treasury Department’s Office of Assets Control’s (OFAC) SDN and other sanctions lists, and you check existing vendors against new additions to OFAC’s lists. But how is your follow-through?
What do you do when you get a name match or what appears to be a match? Do you know what constitutes a match, and when are you required to notify OFAC? These are important questions to answer. Here’s a quick guide with a link below to OFAC’s detailed instructions.
The first thing to know in a potential match of your vendor is which list the hit is against. It’s important to remember that besides the U.S. Treasury Department’s sanction lists of countries, entities and persons, OFAC also aggregates several other government lists. If the hit appears to be from a list from another agency, you need to approach that agency about it.
Those other lists and agencies include:
- The Denied Persons List and the Entities List. (Contact the Bureau of Industry and Security at the U.S. Department of Commerce at 202-482-4811.)
- The FBI’s Most Wanted List or any other FBI-issued watch list. (Contact the Federal Bureau of Investigation at Contact Us — FBI.)
- The Debarred Parties list. (Contact the Directorate of Defense Trade Controls at the U.S. Department of State, 202-663-1282.)
- The Bank Secrecy Act and the USA PATRIOT Act. (Contact the Financial Crimes Enforcement Network (FinCEN) at 1-800-949-2732.)
For SDN or OFAC lists, you want to ensure several similarities exist before considering a match rather than merely the appearance of one. It is not as simple as matching “John Wigglesworth” to “John Wigglesworth” or even Wiglesworth. You must look at additional details of your vendor against those of the possible match.
Look for obvious disqualifiers. If you have a company name but the name on the list is an individual person, it’s not a match. If your vendor’s birth year is 1960, but the birthday of the match is 1995, you don’t have a match. So, check the identifiers you have—age, location, type of entity—against the details of the entity on the list. This will help you eliminate non-matches.
However, if numerous similarities or exact matches exist, it’s time to contact OFAC’s compliance hotline.
Here’s a link to OFAC’s page with step-by-step instructions for answering the question, “How do I determine if I have a valid OFAC match?”
For background on your organization’s responsibility regarding OFAC checking, see OFAC Checking: The Crucial Responsibility of Companies to Comply with Treasury Department Sanctions.
To learn how VendorInfo can help with your sanctions-compliance program, click here.