How to screen a counterparty against OFAC lists, and what a match means
Quick answer, Oct 29, 2026As of 29 October 2026, screening a counterparty against the US sanctions lists is three steps: search the Specially Designated Nationals List and the Consolidated Screening List for the name, aliases and identifiers; apply the 50 Percent Rule to any owners; and treat every hit as a lead to confirm on the official entry, not a decision.
The three steps
- Search the lists. Run the counterparty's legal name, trade names, aliases and identifiers (passport, registration number, IMO, SWIFT/BIC, wallet address) against OFAC's Sanctions List Search and the International Trade Administration's Consolidated Screening List. The SDN List is the OFAC designations list; the Consolidated List adds the other Treasury, Commerce and State lists. Both allow a close-match score so transliterations and misspellings surface.
- Apply the 50 Percent Rule. An entity owned 50% or more, directly or indirectly, in the aggregate by one or more blocked persons is itself blocked, even if it is not on the list. OFAC FAQ 401 sets this out with five worked examples. Map the ownership of the counterparty against known blocked owners before you clear it.
- Confirm or clear each hit on the official entry. A list match is a lead; the official record is the SDN entry on Treasury's SDN List page. Match date of birth, place of birth, national identifiers, addresses and vessel/aircraft details before you call it a hit. The lists change: OFAC Recent Actions is the dated feed.
What the US lists cover
| List | Issuer | What it adds |
|---|---|---|
| SDN List | OFAC (Treasury) | Blocked persons across all programs: individuals, entities, vessels, aircraft and digital-currency addresses |
| Non-SDN consolidated lists | OFAC | Sectoral Sanctions Identifications, Foreign Sanctions Evaders, 13599 List, 561 List, Palestinian Legislative Council List, CAPTA and NS-CMIC |
| Entity List, Denied Persons, Unverified, Military End User | BIS (Commerce) | Export-control restrictions |
| ITAR-debarred, nonproliferation | State | Defense-trade and nonproliferation restrictions |
The Consolidated Screening List combines them in one search, with each entry linking to the issuer's record.
What a match means, and what it does not
A screening match is a lead to check against the official entry, not a determination. Names vary in spelling and transliteration, and commercial-database matches lag the lists. No match is not a clearance: the lists change, your counterparty may be owned 50% or more by a blocked person without appearing on the list, and screening does not read the 50 Percent Rule for you.
A confirmed hit on a blocked person means the counterparty's property and interests in property are blocked and that most transactions with it are prohibited. OFAC's enforcement page sets out past settlements as a reference for what the agency has found material. Where a transaction is otherwise authorised by a general or specific licence, the licence terms are the gate. See the guide on OFAC general licenses: what to check.
In an AI assistant
search_screening_lists on the Distributed Risk MCP server runs the Consolidated Screening List search from Claude, ChatGPT or another client, with the lists' last-changed dates in every answer. list_ofac_actions lists OFAC's recent designations, removals, general licenses and FAQs. Both are read-only and need no key. The desk's recent sanctions notes explain what each new action changes.
When a decision needs people on the ground
A confirmed hit, an ownership question that the record cannot answer, or a counterparty in a jurisdiction you cannot verify from your desk may call for an investigation. Brief an advisor and we arrange it with a partner firm that works there.
Questions
Do I need to screen every party in a transaction? Screen each counterparty and each known beneficial owner. OFAC guidance treats indirect ownership through intermediate entities as covered by the 50 Percent Rule.
What should I file after a hit? Reporting obligations depend on the program and the transaction. OFAC's Reporting, Procedures and Penalties Regulations at 31 CFR Part 501 set the baseline; counsel decides what applies.
Is this legal advice? No. This page is a procedural checklist drawn from the public record.