Practical guide

OFAC screening for insurance: policy and claim party checks

Learn how to check policy and claim parties, review possible OFAC matches, and keep the right records when a beneficiary or payee changes.

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Identify the role and legal party being checked

Use SanctionsKit to check the people and companies your insurance process requires. First list their roles. The policyholder, insured person, beneficiary, payee and agent may be different people. Keep each role and the policy or claim ID in your own system.

A new beneficiary or claim payee may not have been part of the first check. Use OFAC's insurance guidance with your responsible team to decide when a new search is needed. The rules must be applied to the product and the action you plan to take.

Run the approved source comparison

Open New screening. Enter the legal name, person or company type, and facts you trust. Create a saved profile for a party you will check again. Put your own party ID in External reference. Test with invented people in Sandbox before real use.

For an actual check, use authorized Production access. Under Source coverage, choose the approved policy and check that each required source is available. Run screening and save its ID with the right party. If it fails, show the unfinished check to the team responsible for the next step.

Review identity separately from claim validity

Open a candidate in the Review queue. Compare the full entry with the person you mean. State which facts agree, which conflict and which are missing. For a fictional beneficiary with a common name, a trusted date or ID may help resolve the alert. A name alone cannot.

Record who you believe the listed party is and why. Then record the business decision after the needed sanctions review. A score does not tell you whether a claim is valid, covered or payable. A no-match leaves other insurance checks in place. Get a second person's approval when required.

Link only the evidence relevant to the review

Keep original ID documents in your approved file store. An admin adds that service in Settings → Organization documents. Use Link original document in the case, with the file version and where the evidence came from.

Do not copy unrelated medical records into the case. SanctionsKit keeps the link and the reviewer's stated findings, not the original file. Export case evidence for the policy or claim file. A later reviewer should be able to see the search scope, source versions and reasons.

Screen changed parties and own later events

Suppose a fictional policy adds a new beneficiary. Run the required check for the new person. Keep the earlier result and note when the party changed. A later claim payee may need a separate check too; do not reuse another person's result.

Use Monitoring for ongoing parties chosen by your policy. Check that the first run finishes and assign later alerts and failures. The responsible teams still decide which products fall within AML rules, run the wider AML program and make claim decisions.

Sources and references

Frequently asked questions

Can the policyholder's result cover a new beneficiary?

No. The result describes the person or company submitted for that check. Apply your policy to the new beneficiary and run the check it requires. Keep both results linked to the roles each person holds.

Does a possible match establish that an insurance claim is invalid?

No. First review whether the candidate is the same party, then assess the relevant sanctions rule. The team that decides claim validity and payment still needs to complete its own work.

Should medical documents be copied into a sanctions case?

Keep case notes focused on the facts needed for the screening review. Leave original files in approved storage. Link relevant evidence with the right access controls, rather than copying unrelated medical records into the case.

What should insurance teams monitor after the first check?

For parties chosen by policy, confirm the first monitor run and assign later alerts and failures. Also track party changes in the policy or claim file. A new person may need a separate check.