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

Date issued: Apr. 28 2021

TURBOFAC Commentary (167 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).