Use the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) Sanctions List Search as a first screen, then verify any possible name match, investigate the supplier’s ownership, and assess the rules that apply to your particular transaction. A search with no hit is not, by itself, proof that the supplier or transaction is unrestricted.
1. Confirm which company you are screening
“Korean supplier” is not precise enough for a sanctions check. Confirm whether the business is registered or operating in the Republic of Korea (South Korea) or the Democratic People’s Republic of Korea (North Korea), and establish its actual legal identity. Do not infer the applicable restrictions from the word “Korean” alone.
Before searching, collect as many of these details as are available:
- The exact registered legal name, including its local-language form.
- Known aliases, alternate spellings, and Romanized or transliterated versions of the name.
- Country of registration, address, and registration number.
- Names and identifying details for relevant owners and intermediary companies.
These details help distinguish the supplier from another business with a similar name.
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2. Search OFAC’s current sanctions lists
Run an initial manual search in OFAC’s official Sanctions List Search. The tool searches for potential matches on both the Specially Designated Nationals (SDN) List and OFAC’s consolidated non-SDN lists. OFAC also makes current sanctions-list data available through its Sanctions List Service for download.
The lists are not interchangeable. The SDN List concerns blocked persons; non-SDN lists can impose different restrictions tied to particular programs. Note which list produced any result, rather than treating every result as the same kind of prohibition.
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3. Investigate possible name matches
Search the supplier’s legal name and relevant aliases or spelling variants. OFAC’s search uses fuzzy logic to identify possible name matches, so a result is a lead to investigate—not a determination that the supplier is the listed party. A similar name alone does not establish identity.
Compare the result with the supplier’s country, address, registration details, aliases, and other identifying information. OFAC does not set one universal similarity-score threshold that decides every case; its guidance leaves organizations to apply screening procedures appropriate to their circumstances.
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- If the identifying details do not fit: document why you determined that the result is not the supplier.
- If the details match or remain uncertain: do not treat the supplier as cleared on the basis of the name search. Pause the transaction as appropriate and have the potential match reviewed under your compliance process, with qualified advice where needed.
4. Check ownership, including indirect ownership
A supplier does not need to appear by name on the SDN List to be blocked. Under OFAC’s general 50 Percent Rule, an entity is blocked if one or more blocked persons own, directly or indirectly, 50 percent or more of it in aggregate. OFAC FAQ 91, updated August 21, 2024, explains that an entity’s property and interests in property are blocked even when the entity itself is not listed on the SDN List.
Trace the ownership chain through intermediate companies and aggregate the interests of blocked owners. Checking only the supplier’s own name, or only its immediate shareholder, can miss indirect ownership.
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Ownership and control are different questions. OFAC FAQ 398, dated August 11, 2020, states that the 50 Percent Rule speaks to ownership, not control: control without 50 percent ownership does not, by itself, automatically block an entity under that rule. Control or other facts may still create compliance risk or be relevant to a separate designation.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.5. Assess the transaction and applicable program rules
A list search does not answer whether a specific deal is permitted. Consider the buyer’s U.S. connection, the parties and intermediaries, the goods or services, and the jurisdictions involved. OFAC programs differ: a restriction may be program-specific, and a non-SDN listing may not impose the same consequence as an SDN blocking designation.
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U.S. persons generally must comply with U.S. sanctions wherever they are located. Some foreign persons or transactions can also be covered, depending on the applicable rules and facts. Review the current regulations and relevant OFAC guidance, including any authorization or exemption that may apply; do not infer permission or prohibition from a list result alone.
6. Keep a record and screen again when needed
Record enough information for another reviewer to understand what was checked and why you reached your conclusion. Keep the screening date, the list data or version used, names and variants searched, identifying details reviewed, ownership evidence, and the disposition and rationale for any potential hit.
Build repeat screening into appropriate points such as supplier onboarding and before material transactions. Recheck when ownership or identity details change and when sanctions lists are updated. OFAC identifies stale list data and failure to account for alternative spellings as weaknesses in screening systems.
What a screen can—and cannot—establish
A documented search can support an initial compliance decision; it cannot certify a supplier or transaction as unrestricted. This is particularly important where a possible match remains unresolved, beneficial ownership is unclear, North Korea-related facts are involved, or the U.S. connection is complicated. In those situations, assess the current program rules and seek qualified compliance or legal advice before relying on the result.
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