Compliance Guide

OFAC Screening API

How to integrate OFAC SDN, sectoral sanctions, and the 50% Rule into your compliance workflow.

What OFAC screening covers

The US Treasury's Office of Foreign Assets Control (OFAC) maintains multiple sanctions programs. Verifex screens against OFAC SDN, SSI, CAPTA, NS-MBS, CMIC, and PLC lists. Each match includes the specific OFAC program, sanctions basis, and entity identifiers.

OFAC operates under a strict liability regime. You can be fined even if you did not know a customer was sanctioned. Penalties start at approximately $330,000 per negligent violation and can reach $20 million or more for willful violations. This makes comprehensive OFAC screening non-negotiable for any business touching the U.S. financial system.

The OFAC lists explained

SDN — Specially Designated Nationals

The primary OFAC list with 18,700+ entries. Includes individuals, entities, vessels, and aircraft. All transactions with SDNs are blocked. U.S. persons must freeze assets and report to OFAC within 10 business days. Updated multiple times per week.

SSI — Sectoral Sanctions Identifications

Targets specific sectors of the Russian economy (financial, energy, defense). Unlike SDN where all transactions are blocked, SSI imposes targeted restrictions — for example, prohibiting new debt or equity financing with listed entities.

CAPTA — Correspondent Account Sanctions

Prohibits U.S. banks from opening or maintaining correspondent accounts for listed foreign financial institutions. Applies to entities designated under Iran, North Korea, and Russia sanctions programs.

CMIC — Chinese Military-Industrial Complex

Targets Chinese companies with military-civil fusion ties. U.S. persons are prohibited from purchasing or selling publicly traded securities of listed companies.

The OFAC 50% Rule

Under OFAC FAQ 401, any entity owned 50% or more by one or more sanctioned persons is itself considered sanctioned, even if not named on the SDN list. This is called constructive blocking.

The rule applies to direct and indirect ownership. If Company A is sanctioned and owns 60% of Company B, Company B is also blocked. If Company B then owns 60% of Company C, Company C is also blocked — even though the ownership chain is two levels deep. Verifex UBO chain screening calculates aggregate ownership up to depth 10 to catch these constructive blocks.

For a detailed explanation, read our OFAC 50% Rule guide.

OFAC integration checklist

  • Confirm your compliance policy requires OFAC SDN screening
  • Understand the OFAC 50% Rule — constructive ownership through sanctioned entities
  • Screen against OFAC SDN, SSI, CAPTA, NS-MBS, CMIC, and PLC lists
  • Store OFAC match details including programs, sanctions basis, and IDs
  • Log every OFAC screening with list version timestamp for audit
  • Review OFAC sectoral sanctions for industry-specific restrictions
  • Set up UBO chain screening for the 50% Rule (Enterprise)
  • Subscribe to OFAC list updates — Verifex syncs every 6 hours

Compliance caveat: OFAC screening results are decision-support evidence. Final compliance decisions, policy enforcement, and regulatory documentation remain your responsibility. Always review OFAC matches with qualified compliance counsel.

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