What to do with a possible OFAC match

Last updated 2026-11-10 · Starry Night

Screening tools flag names, not people. Most alerts turn out to be someone else with a similar name. OFAC FAQ 5 gives a six-step method for working an alert; here it is in plain English.

The six steps

Which list fired? Decide whether the alert is against one of OFAC's sanctions lists (or otherwise involves an OFAC program), or against a list kept by another agency or organization. Other lists, such as the Commerce Entity List, have their own rules.
Name or place? Decide whether it is a potential match to a listed name, or a link to a country, region or government targeted by sanctions. A listed-name match goes to step 3.
Compare the details. Open the complete list entry and compare everything in it with what you know about your party: full and former names, aliases, nationality, passport, tax and national ID numbers, place and date of birth, business registration numbers, addresses. If you lack the details, gather them (OFAC mentions documents such as a driver's license or corporate registration). Few similarities usually means no valid match. A different date of birth, ID number or nationality is a strong sign it is someone else. A shared address alone proves little, since many businesses can share one address.
Decide. An exact match, or a close match with several matching details and nothing that rules it out, goes through your sanctions procedures as a likely match. OFAC calls this a risk-based decision. For a valid match, check whether an OFAC general or specific license or an exemption covers the activity.
Block or reject. If no authorization applies, determine whether the sanctions require you to block the property or to reject the transaction or stop the activity. Blocked funds go into a segregated, interest-bearing account at a U.S. federally insured institution, from which only OFAC-authorized debits may be made.
Report and record. Report blocked property and rejected transactions to OFAC within 10 business days (31 CFR 501.603, 501.604), and keep records of how you investigated the alert.

Write down the reason

For each alert you clear, note which detail ruled it out (for example "listed person born 1961; our customer born 1988, per passport"). That one line is what a reviewer looks for later. The record should also say which list version you screened against, since lists change weekly.

Cutting false positives without missing real matches

Screen with a country or date of birth when you have it, so the review starts with the strongest identifiers.
Decide in your procedure how you treat weak aliases; OFAC explains them on its weak aliases FAQ page.
Keep the threshold steady between runs and document any change.

Every possible match, side by side, in one record

The screening record page screens up to 500 customers, suppliers or vessels at once against the U.S. Consolidated Screening List (OFAC, BIS and State Department lists), the UN Security Council Consolidated List, the UK Sanctions List and the EU consolidated financial sanctions list, with name matching that handles word order, transliteration variants and small typos, and builds a dated PDF record of the run. On-screen results and a PDF marked PREVIEW are free; a $29 one-time unlock removes the watermark for 24 hours. Names are not stored.

Screen a list

Each possible match in the record shows the listed names, programs, identifiers and a link to the publisher's entry, plus a reviewed-by block where you note the outcome.

Checking a few names while you work in Claude? The free Sanctions & Tariff Lookup connector screens a name from a chat and shows each possible match with its list, programs and identifiers. No sign-up with Starry Night is needed.

This guide explains public rules and OFAC guidance in plain English. It is not legal advice; for a decision about a specific party or transaction, talk to sanctions counsel or contact OFAC. Sanctions & Tariff Lookup is published by Starry Night and is not affiliated with OFAC, the Department of Commerce, the State Department, the UN, the UK government or the European Commission.

Questions

Does a name match mean the party is sanctioned?

No. OFAC FAQ 5 says many potential matches are false positives. You compare the full list entry (aliases, birth dates, nationality, ID numbers, addresses) with what you know about the party before deciding.

How soon must a blocked or rejected transaction be reported?

OFAC FAQ 5 says reports of blocked property and of rejected transactions are due to OFAC within 10 business days, under 31 CFR 501.603 and 501.604.

What is a weak alias?

An alias OFAC flags as weak (for example a short or common nickname). OFAC FAQ 5 says a screening tool may exclude weak aliases as part of a risk-based decision.