OFAC applies to your closing whether or not SB 17 does.

The Office of Foreign Assets Control publishes the Specially Designated Nationals list and the Consolidated Sanctions List. United States persons, including title agents, brokers, lenders, and landlords, may not transact with listed persons or entities they own. This is federal law under IEEPA and 31 CFR chapter V, and it is not new.

What a screen is

A comparison of a name against the current lists, including known aliases. ParcelClear ingests the SDN and Consolidated lists directly from Treasury every six hours and records the list date on every screen. A screen against a list older than seven days is not a result; it is a HOLD.

What a potential match means

A name similar to a listed name. Most potential matches are false positives: common names, transliterations, partial overlaps. A reviewer looks at the listed entry, the aliases, the program, and the facts of the transaction, then records a disposition with a reason. The disposition is logged and printed in the record. A true match stops the transaction and is a matter for counsel and OFAC, not for this software.

Why the list date matters

The lists change weekly. A screen is only evidence of what the list said on the day you asked. The record prints the list version and the date so that a later reader knows what you could have known.

What a record shows

Every party and control person screened, the list date, the score and the listed entry for each potential match, the reviewer's disposition and reason, and the hash. Watch re-screens the parties on finalized records against each new list and emails the record id when a new potential match appears.

Common questions

Q: Does a NO_MATCH result mean the buyer is not sanctioned? A: It means the names you entered did not match the lists on that date above the threshold. It is evidence of a screen, not a determination about a person.

Q: Is this a background check? A: No. It is a comparison against public United States government sanctions lists. It contains no credit, criminal, eviction, or employment information.

Q: Do I have to screen? A: OFAC prohibitions apply to every United States person. Whether to screen, and how, is a decision for your office and your counsel. This page is not legal advice.

Q: What happens on a true match? A: The record shows REPORT. The transaction is a matter for counsel and for OFAC. ParcelClear does not file anything with any agency.

See what the record looks like.

The sample uses fictional names and a fictional hash. It cannot be verified and it is not a record.