Practical guide
OFAC screening for title companies: a closing-file workflow
Connect required OFAC checks with the closing roster, resolve candidate matches and recheck changed payees before the settlement decision.
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Prepare the closing roster and review roles
A title or settlement team needs evidence for the parties at its chosen checkpoint. List purchasers, sellers and other required parties by legal name, role and closing-file reference. Another provider's check does not tell you which identities or sources it covered.
Use separate subjects for an entity buyer, signatory and payee when they are in scope. In SanctionsKit, confirm who can screen, review and approve. Test the handoff with fictional closing parties in Sandbox.
Link each result to the right closing party
In New screening, enter the legal party, subject type and reliable dates or typed identifiers. Create a saved profile when it should be reused, with the closing system's party ID in External reference. Inspect an existing profile before using it.
Apply the approved policy and confirm required Production coverage is available. Run screening and save its ID with the roster. Sandbox uses synthetic records; a failed Production request leaves the check incomplete.
Make the outstanding identity question clear
Open a candidate in the Review queue and assign a reviewer. Read the full source entry and compare reliable identifiers. Record what fact is missing and leave the finding unresolved if the evidence is insufficient.
If a fictional seller produces an alert shortly before closing, obtain the specific missing fact through the approved channel. Do not lower a threshold to make the alert disappear. Keep the identity finding separate from instructions about escrow or disbursement.
Attach outside checks and original-document references
Require ownership or authorization assessments through Screening policies when needed. The reviewer records completion and an evidence reference. SanctionsKit does not conduct that research or decide whether the transaction is authorized.
Keep contracts and ID documents in approved external storage, then use Original document references in the case. Assess residential real estate reporting separately using FinCEN's current notice. A sanctions result cannot answer that reporting question.
Check final payees before the settlement handoff
Compare amended payment instructions with the roster. In a fictional closing, a seller introduces another company as payee. Identify and screen that company when required; the seller's result does not describe the new payee.
Confirm each required subject has a completed comparison, with candidate findings, outside checks and approvals recorded. Export case evidence and keep the case ID in the closing file. Leave failures and unresolved questions visible to the person allowed to decide.
Sources and references
Frequently asked questions
Can a title team rely on the lender saying screening was done?
First confirm the parties, sources, timing and evidence behind that statement. Compare them with the title team's own procedure. A check performed for another purpose may not cover the final closing roster.
What should an urgent closing alert handoff include?
Give the reviewer the case reference, correct party, source entry and specific missing identity fact. Keep the closing at its required checkpoint while evidence or approval is pending, rather than asking for an unsupported dismissal.
Should a changed disbursement payee receive a new check?
Apply your procedure to the new legal payee as a distinct subject. Keep the earlier party's result and connect the new result to the payment amendment. Do not relabel the old result.
Does a closed case instruct the escrow team to release funds?
The case records the screening review and business disposition. Your authorized settlement process controls disbursement and any required payment action. Make that handoff explicit so a result label is not mistaken for an instruction.