Practical guide
OFAC screening for lenders: check borrowers and loan parties
Screen required borrowers and guarantors, retain each result with the loan, and handle changed parties before funding and servicing handoffs.

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Map the loan to its legal parties
Use SanctionsKit at the application, funding or other checkpoint your lending procedure requires. List each borrower, co-borrower, guarantor and other required party. A business borrower and the person submitting the form are separate identities.
Keep the loan reference and party roles in the loan system. Screening supplies one piece of the file. It does not assess income, collateral, creditworthiness or eligibility for the loan.
Run the check and save its party reference
Open New screening. Use fictional borrowers in Sandbox for testing and authorized Production coverage for real work. Enter the legal name, type and reliable identifiers. Preserve a year-only birth date as a year.
Create a saved profile for future checks or inspect an existing one. Put the party ID in External reference. Apply the approved Source coverage policy and Run screening. Save the result against the specific loan party; names alone are not a reliable way to join records.
Give the analyst the original comparison
In the Review queue, compare every candidate's identifying facts. A reliable conflicting date may help, but a missing date is unknown. Record each finding and reason, then complete outside checks and approval by a second person when required.
Keep the identity finding separate from the loan decision by the person with that role. A no-match is limited to the supplied facts and source scope. A failed request or required-source outage leaves this part of the loan file incomplete.
Handle a new guarantor or corrected borrower
If a fictional commercial loan gains a guarantor after application review, screen that person separately and link the new result to the loan. The borrower's earlier result cannot cover the guarantor.
Correct saved identities through Counterparties and run the required new comparison. Past evidence stays unchanged, and linked monitors need reconciliation. For an open case, use the correction workflow to preserve the relationship between original and replacement results.
Prepare the funding and servicing handoff
Before the agreed funding step, reconcile the roster with results, open cases and failures. Export retained records through evidence documentation and keep the reference with the loan. Originals stay in approved external storage.
Use Monitoring for subjects your policy says to check again and assign follow-up. These checks rescreen identity; they do not monitor payment performance or refresh income. Use the approved retention trigger rather than assuming loan closing and case closure are the same event.
Sources and references
Authority and technical sources
- OFAC FAQ 11: who must comply (opens in a new tab)
- OFAC FAQ 5: assessing a possible match (opens in a new tab)
- FFIEC BSA/AML examination manual: OFAC (opens in a new tab)
- 31 CFR 501.601: records and recordkeeping requirements (opens in a new tab)
- OFAC: final rule extending certain recordkeeping requirements (opens in a new tab)
Frequently asked questions
Does borrower screening assess loan eligibility?
No. It compares the supplied identity with selected sources. Income, credit, collateral and eligibility remain separate lending assessments. Keep the screening finding and the authorized loan decision clearly distinguished in the file.
What should happen when a guarantor is added after application review?
Treat the guarantor as a separate subject and run the required check. Link its result to the existing loan, preserve prior results and complete any new review before the relevant lending checkpoint.
Why should loan results be linked by party ID instead of name?
Names can be shared, changed or recorded differently. A stable party reference connects each screening to the intended borrower or guarantor and helps the team reconcile the full roster before funding.
Does borrower monitoring track missed payments?
No. SanctionsKit monitoring creates later identity checks against selected sources. Loan performance and income reviews need separate controls. Assign a team to handle screening events and failures alongside those servicing duties.