How to screen real estate transaction parties for OFAC matches

Create a roster of the actual transaction parties

Use SanctionsKit to record the checks your real estate process requires for buyers, sellers and other parties. Keep the transaction ID and each role in your transaction system. A property address or project name belongs in that context, not in the subject's name field.

A company buyer and its signatory are separate legal parties. Add owners or representatives when your team's policy requires them. SanctionsKit screens the identities you submit; it does not find beneficial owners or calculate an ownership chain.

Screen each party under the approved scope

Open New screening. Practice with fictional parties in Sandbox before using permission to use Production for real checks. Enter the legal name, correct subject type and known identifiers. For a company, preserve the registration ID's type and issuer.

Create a saved profile with an ID your closing team can match to the file, or check the identity on an existing profile. Choose the approved policy or permitted sources and Run screening. Copy the result ID into the roster. If a required source is unavailable, the check is incomplete.

Keep ownership work beside the name check

A company name no-match does not resolve OFAC ownership restrictions. Assign that work to the responsible team. An owner or administrator can require an external check in Screening policies.

In the case, link the review record and whether the work was completed externally. If it does not apply, give the reason. A checked box is not an ownership investigation. Keep the supporting records in approved storage and link the relevant document.

Resolve each candidate before the handoff

Open the Review queue and compare each candidate with the right party in the deal. For a fictional company buyer, a trusted company ID may distinguish a similar-name entry. An office shared by many companies is weak evidence on its own.

Record whether you think it is the same party and why. The responsible team then assesses the planned activity and records the business decision. Get a second person's approval when required. A no-match case may still need outside checks; finish them before closing the review.

Reconcile the roster again at the closing checkpoint

Compare the final parties with Screening history. A new buyer, intermediary or payment recipient may need another check. Keep the earlier result and connect the new one to the change in the deal.

The teams that verify payments and assess reporting duties still need to do that work. Check FinCEN's current residential real estate notice for reporting status. Export retained case records through the evidence workflow; a sanctions outcome does not answer those separate questions.

Frequently asked questions