Wondering if you're on an OFAC sanctions list? Don't panic - it's easier than you think to find out. OFAC, or the Office of Foreign Assets Control, maintains several lists of individuals and organizations who are subject to economic sanctions by the U.S. government. Being on one of these lists means your assets could be frozen, and U.S. citizens and companies are prohibited from doing business with you. Let's walk through the steps so you can check if your name is on there.

What is OFAC?

OFAC is an office within the U.S. Department of Treasury that administers and enforces economic and trade sanctions. These sanctions target foreign countries, regimes, terrorists, international narcotics traffickers, and those engaged in activities like proliferation of weapons of mass destruction, human rights abuses, cyber crimes, and more. OFAC acts under presidential national emergency powers and certain legislation to impose controls on transactions and freeze assets under U.S. jurisdiction.

OFAC's Sanctions Lists

OFAC maintains several different sanctions lists:

• Specially Designated Nationals (SDN) List - individuals and companies owned/controlled by targeted countries, as well as terrorists, narcotics traffickers, and others.
• Sectoral Sanctions Identifications (SSI) List - individuals and entities subject to limited sanctions under certain Executive Orders.
• Foreign Sanctions Evaders (FSE) List - foreign persons who have violated U.S. sanctions on Syria or Iran.
• Non-SDN Lists - Palestinian Legislative Council, Chinese military companies, etc.

How to Search the Lists

OFAC makes it easy to search their sanctions lists through the Sanctions List Search tool on their website. This search uses fuzzy logic to catch potential matches - so even if you don't have an exact match, it will flag possible hits for further review. Here are the steps:

1. Go to https://sanctionssearch.ofac.treas.gov/
2. Select the list(s) you want to search - start with the SDN list
3. Enter your first and last name in the search fields (you can also search addresses, cities, etc.)
4. Hit "Search" and see if you get any matches

If you don't get an exact match, look for results with a high match percentage - this means OFAC's algorithm flagged it for potential review. If you're concerned about a possible match, gather documentation about your identity, nature of business, etc. and consult OFAC's guidance on verifying matches.

What to Do If You're Listed

If you find you are on an OFAC list, don't panic. You have options:

• File a request with OFAC to be removed from the list if you believe your designation was made in error.
• Petition for reconsideration if you believe circumstances have changed to warrant it.
• Apply for a specific license from OFAC to allow you to engage in certain transactions you otherwise couldn't.
• Hire an attorney experienced with OFAC cases to represent you.

The process won't necessarily be quick or easy, so be prepared for a long road ahead. Consult qualified legal counsel to protect your rights and advocate on your behalf. Be cooperative, communicative, and transparent with OFAC to help demonstrate you do not belong on the sanctions list and get your name removed as soon as possible.

Avoid Getting Listed in the First Place

Here are some tips to avoid getting sanctioned by OFAC:

• Screen all customers, partners, vendors against OFAC lists before transacting.
• Implement compliance procedures to identify and halt prohibited transactions.
• Understand U.S. sanctions laws and your risks when operating internationally.
• Consult legal counsel experienced with OFAC regulations.
• Conduct due diligence on foreign business partners and investments.

Staying off OFAC's radar requires vigilance, but it's far better than trying to get removed once you're already on a sanctions list. Be proactive, seek advice when needed, and take measures to confirm you are not transacting with listed individuals or entities. Dealing with OFAC listings can be complex, but there are always options no matter your situation. The key is staying calm, getting good advice, and taking the right steps. With patience and perseverance, you can get through the process successfully.

References

OFAC Sanctions List Search Tool OFAC FAQ on Searching Sanctions Lists OFAC FAQ on Verifying SDN Matches OFAC Specially Designated Nationals (SDN) List