OFAC FAQ (Current) # 246 - Sanctions Search List Questions

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (243 words)

Notes:

Consult the enforcement action research module for other enforcement actions categorized as having been the result of automated filtering problems, including failures to return items deemed sufficiently close to that which appears on the list.

In National Bank of Pakistan (2015), OFAC explained that:

On May 31, 2013, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Kyrgyz Trans Avia, an airline headquartered in Bishkek, Kyrgyzstan, pursuant to Executive Order 13224 of September 23, 2001, "Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism." Between June 6, 2013 and January 31, 2014, NBP New York processed seven funds transfers totaling $55,952.14 that were originated by, or destined for, the account of "LC Aircompany Kyrgyztransavia" at the National Bank of Pakistan’s branch in Bishkek, Kyrgyzstan ("NBP Bishkek"). NBP New York’s OFAC interdiction filter failed to generate an alert or identify any potential matches to OFAC’s List of Specially Designated Nationals and Blocked Persons (the "SDN List") when it screened the funds transfers for review, and the bank processed all seven of the transactions forward.

As of 12/2020, almost seven years after the violation, LC Aircompany Kyrgyztransavia still returns no results on OFAC's SDN search tool when the "Minimum Name Score" bar is set to 81. At 80, it returns a hit. That is as strong a message as OFAC can send that it expects a setting of least 80 for banks.

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OFAC FAQ (Current) # 246 - Sanctions Search List Questions

TURBOFAC Commentary (243 words)