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OFAC FAQ (Current) # 892 - How to Search OFAC's Sanctions Lists

Date issued: Apr. 28 2021

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892. What is the difference between the previous version of Sanctions List Search, and the upgraded version made live to the public on January 25, 2021?

OFAC’s Sanctions List Search application has been available to the public since 2011. Over the years the tool’s userbase grew to a point where the original infrastructure and design for the application could not keep up with demand. In late 2020, OFAC took steps to increase the tool’s efficiency to improve its performance.

The primary update was the addition of a new algorithm to the tool’s fuzzy logic search functionality. The upgraded application still utilizes the original Soundex and Jaro-Winkler algorithms in addition to the new algorithm (see this link for more information on the upgrade). As a result of this update, users may see differences in search results when compared to an earlier version of the tool. If users had previously tested Sanctions List Search in order to determine how the tool could assist in their due diligence, it is recommended that such testing be repeated on the current version of the tool. OFAC may continue to periodically update and/or make changes to the tool. While OFAC has no immediate plans to further upgrade the application’s fuzzy logic functionality users should watch OFAC’s website for information about future upgrades. As such, users are to advised that they are using a free service at their own risk, and that best practice dictates each user performs baseline checks to see how updates/changes to the tool may affect search results.

For more information regarding how the tool works and calculates scores, please refer to FAQs 246, 247 and 249. For more information on who may use the tool, please see FAQ 287.

Date Released
April 28, 2021
External link location:
https://ofac.treasury.gov/faqs/892

TURBOFAC Commentary (164 words)

Notes:

1) Unlike all or virtually all other original OFAC FAQs issued in recent years, FAQ # 892 was issued without a corresponding notice on OFAC's "recent actions" page. (https://ofac.treasury.gov/recent-actions). It is possible that the impetus behind the FAQ was the release, the following day, of Civil Enforcement Information - MoneyGram Payment Systems, Inc. In that enforcement release, OFAC noted that "[o]nce MoneyGram began screening [ ] transactions [related to federal inmates that it had previously not screened], it nonetheless continued to process transactions on behalf of blocked persons in federal prisons due to other screening, technology, and fuzzy logic failures, as well as limited instances of human error."

2) See Civil Enforcement Information - Payoneer Inc., referencing use of "weak algorithms" for screening as an aggravating factor. OFAC does not say whether use of only "the original Soundex and Jaro-Winkler algorithms" previously used for OFAC's own screening tool would now qualify as insufficient due diligence, but it seems likely (at least for payment processors).