OFAC Report

Screening is one of the most important compliance steps related to the laws and regulations overseen by the Office of Foreign Assets Control (“OFAC”); it is a prudential measure to assist in preventing violations. Transactions (e.g., grants and other contracting situations) with ministry partners should be screened against the OFAC list of Specially Designated Nationals (“SDN”). This tool was developed to aid those searches. However, regardless of whether the tool is used to aid the SDN searches, Steps 1, 3, 4, and 5 should be undertaken by offices which wish to initiate the transaction.

Step 1) Determine what names should be screened. Generally, this will be:

Organization name,
Name of organization’s head,
Any individual, subgrantee, and/or company noted in a grant request, application, or reporting who will receive funds via a partner (e.g., stipend to a student from a grantee educational institution, or payment to a company for service provided to partner necessary for the accomplishment of the grant’s purpose), and
Name of organization’s treasurer or person that handles the money.

In certain circumstances, other names will be screened. Those situations are determined in consultation with the Office of Legal & Risk Management Services based on the risk profile for the country involved, the path of disbursement, and the type of activity that will occur. Examples include, but are not limited to:

Situations involving an embargoed country such as Syria in which cash or vouchers will be given to individuals rather than material items such as food and blankets.
Situations in which the transaction is disbursed to the end recipient via a third country and intermediary partner. In such cases, the intermediary would be screened as well.

Please contact April Davenport, Deputy General Counsel, with any questions or situations that seem outside the norm for your work.

Step 2)

Use this tool by clicking 'Next' after reviewing the information on this page.¹

¹Manual searches of the OFAC list may continue to be done via https://sanctionssearch.ofac.treas.gov/

Step 3)

Provide information regarding the names screened and the result of the OFAC screening with your web invoicing request to the Accounts Payable Office.

Step 4)

Retain the information regarding the names screened and the result of the OFAC screening including, but not limited to, any escalations or resolutions of potential matches (see Step 5 below) as evidence of steps taken to comply with the law. These records should be retained with the office’s grant or other file related to the transaction. The office which is responsible for the transaction should retain these records for at least 5 years. These records may be needed in the case of an inquiry from OFAC.

Step 5)

For positive “hits” on the SDN list or questions, immediately contact April Davenport in the Office of Legal & Risk Management Services so that further investigation can occur in order to determine whether the transaction can proceed.