Pause the affected transaction while you verify the supplier’s identity, identify the exact list and restriction, and assess the transaction facts. A screening hit is a reason to investigate—not a single, automatic legal outcome. OFAC sanctions and BIS export-control lists have different effects, and the right response depends on the specific entry, transaction, and any relevant U.S. jurisdictional connection.
What to do first when a screening alert appears
- Put the affected activity on hold. Pause the transaction or activity covered by the alert while it is reviewed. Route it promptly to your sanctions or export-control compliance lead, or to qualified counsel. This is a prudent internal control; a hit does not by itself establish that every relationship must end or that every list independently requires a blanket stop.
- Preserve the alert. Save the screening result and note when and how it was generated. Avoid deleting or changing records relevant to the transaction while the review is open.
- Assign an owner and track the review. Record who is responsible for resolving the alert and what transaction activity is paused. Do not release the hold until the review supports a documented decision.
How to check whether the supplier is actually the listed party
Compare the supplier with the official list entry using more than the name string. Check the listed name and aliases against available identifiers such as address, country, registration information, and other identifying descriptors. OFAC cautions that apparent name matches can be false positives when the other identifying information does not fit.
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Record which identifiers you compared, what matched or differed, the official source consulted, and the date of access. If the available information does not resolve the identity, keep the hold in place while seeking clarification rather than treating an inconclusive name match as either a confirmed match or a clearance.
Which list is it, and what does that list require?
Record the issuing agency, the specific list, and the exact entry. A consolidated screening result helps find potential hits but does not, on its own, explain the legal effect. BIS says its Consolidated Screening List (CSL) combines export-screening lists from Commerce, State, and Treasury; the underlying lists have distinct requirements. Confirm the current record with the agency that maintains the list, then read any linked order, sanctions program, or applicable Export Administration Regulations (EAR) provision.
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| Alert source | What the restriction generally concerns | What to establish for this transaction |
|---|---|---|
| OFAC SDN or other blocked person | U.S. persons are generally prohibited from dealing with blocked persons. Property and interests in property within U.S. jurisdiction, or in a U.S. person’s possession or control, may have to be blocked. | Confirm identity, ownership, applicable program, property interest, and relevant U.S. jurisdictional connection. Check whether blocking and reporting obligations apply. |
| OFAC non-SDN list | Some OFAC lists impose restrictions that are not the same as a blocking designation. | Identify the exact list and program restrictions; do not infer that every OFAC entry requires blocking. |
| BIS Denied Persons List (DPL) | BIS describes listed parties as having denied export privileges under EAR Parts 764 and 766. | Read the denial order and determine whether the contemplated dealings fall within its scope. |
| BIS Entity List | For specified items, the EAR can impose license requirements and limit license exceptions when listed entities or relevant addresses are parties to a transaction. | Determine whether the items are subject to the EAR and check the exact entry’s license requirements and applicable restrictions. |
| BIS Unverified List (UVL) | BIS identifies parties whose bona fides it has been unable to verify; specified transactions require a UVL statement before proceeding. | Determine whether the transaction is covered and obtain the required statement before proceeding, if applicable. |
How to assess the transaction and U.S. connection
Do not assess the supplier name in isolation. Map the contemplated transaction and the supplier’s role, then compare those facts with the identified list entry and rule.
- Parties and roles: identify the supplier, buyer, intermediaries, consignee, end user, and any other parties covered by the relevant restriction.
- Items or services: describe the goods, software, technology, or services involved. Where an EAR restriction may apply, establish whether the item is subject to the EAR and what the applicable entry requires.
- Transaction route: record origin, destination, delivery path, payment path, and the parties handling property or funds.
- U.S. nexus: assess whether U.S. persons, U.S.-jurisdiction property, or other relevant U.S. connections bring the activity within the applicable rule. The answer depends on the rule and facts; a supplier’s location alone does not resolve it.
- Authorization: determine whether a license, authorization, or other applicable permission covers the exact parties, items, and activity. Do not assume an authorization applies without checking its scope and conditions.
When an OFAC ownership check matters
For a potential OFAC blocked-person match, check ownership as well as the supplier’s listed name. Under OFAC’s 50 Percent Rule, an entity is blocked if one or more blocked persons own, directly or indirectly and in aggregate, 50 percent or more of it—even when the entity is not separately named on the list. Assess the ownership chain and the applicable OFAC guidance rather than relying only on a name-screening result.
Choose the disposition after the facts are reviewed
The appropriate response depends on the list, the transaction, and whether property in which a blocked person has an interest is involved. OFAC distinguishes blocking from rejection: a prohibited transaction without a blockable interest may need to be rejected, while property subject to blocking rules must be blocked. Do not treat the two actions as interchangeable; determine the applicable handling, reporting, and deadline requirements with qualified advice.
- Release the alert if documented identity checks establish that it is a false positive.
- Proceed under authorization only if a valid license or other applicable authorization covers the specific activity and its conditions are met.
- Continue the hold if identity, ownership, list scope, or transaction facts remain unresolved.
- Reject or block as required after determining which rule applies and whether the relevant property or transaction is covered.
What to keep in the case record
Keep a record that allows another reviewer to understand both the evidence and the decision. Include the screening alert; official list and access date; identifiers compared; ownership findings; parties, items, routes, and U.S. nexus considered; applicable rule or order; authorization review; decision and approver; and material communications or agency guidance. Re-screen as appropriate because list entries can change. If a BIS restriction remains unclear, BIS publishes separate inquiry contacts for its lists; consult the relevant channel or the appropriate OFAC program resources.
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