U.S. Department of the Treasury — Office of Foreign Assets Control

OFAC Sanctions Screening for Companies with US Exposure

We screen individuals, entities and transactions against every US Treasury sanctions list — SDN, Consolidated Sanctions, and country-specific programs — and deliver a documented sanctions risk report. One-time screening or continuous monitoring.

What Is OFAC and Why Does It Matter for Your Business?

The Office of Foreign Assets Control (OFAC) is a division of the U.S. Department of the Treasury that administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals. OFAC maintains lists of individuals, entities, and countries subject to sanctions — and prohibits U.S. persons and any party with a US nexus from doing business with them.

Importantly, OFAC sanctions are not limited to U.S. companies. Any transaction that touches a U.S. person, uses U.S. dollars, involves U.S.-origin goods, software, or services, or passes through the U.S. financial system falls under OFAC jurisdiction — regardless of where your company is headquartered. A bank in Colombia, a fintech in Mexico, or an exporter in Spain can face OFAC penalties for a single non-compliant transaction.

OFAC violations carry strict liability: the U.S. government does not need to prove you intended to violate sanctions. If a prohibited transaction occurred, you are potentially liable — whether or not you knew the counterparty was sanctioned. Learn more at ofac.treasury.gov.

Types of OFAC Sanctions Lists and Programs

In practice, OFAC maintains multiple overlapping lists. Screening only the most popular one (the SDN List) is not sufficient and can create a false sense of compliance.

OFAC List / Program	Description	Who It Affects
SDN List (Specially Designated Nationals)	Individuals and entities blocked by OFAC. Assets are frozen; transactions prohibited.	All parties with any US nexus
Consolidated Sanctions List	Combined database of all OFAC sanctions lists	All parties with any US nexus
CAPTA / SSI (Sectoral Sanctions IDs)	Restrictions on specific sectors of targeted economies (e.g. Russian energy, finance, defense)	Companies trading with those sectors
CACR (Cuba)	Comprehensive sanctions — most Cuba-related transactions require OFAC authorization	Exporters, financial institutions
OFAC 50% Rule	Entities owned 50% or more by a sanctioned person are also treated as SDN — even if not listed by name	All screeners
Geographic / Country Programs	Country-specific sanctions (Iran, Syria, North Korea, etc.)	Any trade with those jurisdictions

The 50% Rule is Critical

A company can be treated as blocked even if it does not appear by name on any list, if a sanctioned person owns 50% or more of it. This cannot be detected by simple name-match screening — it requires ownership structure analysis.

OFAC Penalties: What Non-Compliance Can Cost You

As a result, OFAC penalties for sanctions violations are among the highest in U.S. regulatory enforcement. Civil penalties can be assessed even without criminal intent.

Violation Type	Maximum Civil Penalty	Criminal Penalty
Non-egregious violation	Greater of $368,136 or twice the transaction value	Up to $1M + 20 years prison
Egregious violation	Greater of $1,470,522 or twice the transaction value	Same
Export control violations (combined)	Up to $1.3M per violation	Up to $1M + 20 years

Real Enforcement Cases

◼ A major international bank paid $8.9 billion for OFAC violations involving sanctioned Iranian transactions processed through U.S. dollars.
◼ A mid-size payment processor paid $29 million for failing to screen against Cuba sanctions.
◼ A pharmaceutical company paid $3.5 million for transactions with a sanctioned Iranian entity routed through a third country.

Beyond fines: OFAC violations can result in loss of correspondent banking relationships, reputational damage, and criminal prosecution of executives.

Who Must Comply with OFAC Regulations?

Any party involved in a transaction with a U.S. nexus is subject to OFAC. This includes:

Importers and exporters trading goods or services with U.S. buyers or suppliers
LATAM and European banks that process USD transactions through U.S. correspondent banks
Fintechs and payment processors handling USD or US-linked payments
Law firms and notaries conducting cross-border due diligence involving U.S. parties
Real estate companies with U.S. investors or financing
Private equity and venture capital firms with U.S. limited partners
Any company with a U.S. subsidiary — the subsidiary’s OFAC exposure can extend to the parent

Your bank is not enough.

Your correspondent bank screens to protect its own exposure and license. They will block a transaction — but the OFAC liability still lands on your company. You need your own documented screening process.

Common Misconceptions

“We operate from LATAM, OFAC doesn't apply to us.”

False. OFAC applies to any transaction with a US nexus — USD, a US person, or US-origin goods or services.

“Our bank handles this.”

The bank protects its own exposure — the penalty still lands on your company.

“I can check OFAC for free on Treasury's website.”

The public tool doesn't document results, doesn't resolve homonyms, and doesn't cover sectoral or geographic programs continuously.

“It's expensive.”

A single civil penalty can exceed USD 1M. Professional screening is a fraction of that cost.

What Our OFAC Screening Service Includes

Therefore, our OFAC compliance screening covers all required lists and delivers a documented record you can present to banks, auditors, or regulators.

What We Screen

SDN List (Specially Designated Nationals and Blocked Persons)
Consolidated Sanctions List (all OFAC programs combined)
Non-SDN sectoral sanctions (SSI, CAPTA, CACR, DPRK, Iran, Syria programs)
50% Rule analysis (ownership structure review for sanctioned beneficial owners)
Adverse media screening (negative news linked to sanctions risk)

What You Receive

Sanctions Risk Report with clear Pass / Fail / Review result
Record of all lists screened and date of screening
Homonym resolution documentation (false positive management)
Recommended next steps if a match is identified
Certificate of screening suitable for correspondent bank disclosure

Available Options

One-time screening — specific individual, entity, or transaction

Batch screening — customer or vendor portfolio (100–10,000+ names)

Ongoing monitoring — continuous screening with alerts when new sanctions are added

Our OFAC Screening Process — Step by Step

Submit Subject Information

Full legal name, aliases, country, ID number, date of birth (individuals) or registration number and country of incorporation (entities).

Multi-List Automated Search

We run the subject against all current OFAC lists plus adverse media databases. Results are captured with timestamps.

Manual Homonym Resolution

Any potential match is reviewed by a compliance specialist to determine if it is a true match or a false positive, preventing unnecessary transaction blocking.

50% Rule Analysis

For entities, we review available ownership structure to identify any OFAC-sanctioned beneficial owner at or above the 50% threshold.

Sanctions Risk Report Delivery

You receive the complete documented report within 24–48 business hours of submission. Expedited screening available for time-sensitive transactions.

Why Choose Compliance Officers for OFAC Screening?

Miami-Based, US-LATAM Expertise

We understand both the U.S. regulatory framework and the operating reality of Latin American and Spanish businesses.

Every List, Every Time

We do not rely on a single database or a public website search. We screen all active OFAC programs.

Documented Results

Every screening produces a time-stamped report acceptable to correspondent banks, auditors, and regulators.

Homonym Resolution Included

We prevent false positives from blocking legitimate business. We don't just flag matches — we analyze them.

Bilingual Service

Full bilingual service — Spanish and English — for your team. Reports available in both languages.

Frequently Asked Questions About OFAC Screening

Does OFAC apply to companies outside the United States?

Yes. OFAC jurisdiction extends to any transaction with a U.S. nexus — including use of U.S. dollars, involvement of a U.S. person or entity, U.S.-origin goods or technology, or processing through the U.S. financial system. A LATAM company using USD to pay a supplier must comply with OFAC even if neither company is U.S.-based.

What is the difference between the SDN List and the Consolidated Sanctions List?

The SDN (Specially Designated Nationals and Blocked Persons) List is the core OFAC list of completely blocked individuals and entities. The Consolidated Sanctions List includes the SDN List plus all other OFAC program lists (sectoral sanctions, non-SDN lists, etc.). Compliance requires screening all lists — not just the SDN.

What is the OFAC 50% Rule?

Under the 50% Rule, any entity owned 50% or more (directly or indirectly) by one or more SDN-listed persons is itself treated as blocked — even if the entity does not appear by name on the SDN List. This is one of the most commonly missed compliance requirements and requires ownership structure analysis beyond simple name matching.

How often should we screen our customers and vendors?

You should screen at onboarding and re-screen whenever new OFAC designations are published (which can happen multiple times per month). For high-risk counterparties or high-value transactions, ongoing continuous monitoring is recommended.

Can I screen OFAC for free on the Treasury website?

The U.S. Treasury provides a free public search tool at sanctionssearch.ofac.treas.gov. However, it does not produce a documented audit trail, resolve homonyms, cover all active programs consistently, or screen for ownership-level exposure under the 50% Rule. For compliance purposes, you need a formal screening process with documented results.

What happens when we identify a potential OFAC match?

If a subject matches an SDN name, you must immediately stop the transaction, freeze any assets involved (if applicable), and report the match to OFAC via the Blocking/Reject Report. Failure to do so can constitute an additional violation. Our team provides guidance through this process.

How quickly can you deliver an OFAC screening report?

Standard turnaround is 24–48 business hours. Expedited screening for urgent transactions is available upon request.

Do you offer ongoing monitoring for a customer or vendor portfolio?

Yes. We offer batch and continuous monitoring plans for portfolios of any size. You receive automated alerts when a match is detected, along with our analysis of whether it is a true match or a false positive.

Start Your OFAC Compliance Process Today

In short, sanctions exposure is not theoretical — it costs companies millions in fines and can destroy correspondent banking relationships that took years to build. Every day you operate without a documented OFAC screening process is a day of unquantified liability.

Our sanctions compliance team is ready to help you build or improve your OFAC screening program, starting with a no-obligation consultation.

Request Your OFAC Screening Talk to a Compliance Specialist

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