Practical guide
Who must comply with OFAC, and which parties should you check?
Understand the scope of OFAC compliance and build a party roster that keeps customer, company, owner and payment-recipient checks distinct.
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Start with the applicable rules
OFAC states that U.S. persons must comply with its sanctions, and certain restrictions also affect non-U.S. persons. The scope depends on the program and facts; OFAC FAQ 11 explains the starting point. The question is broader than whether your business is a bank.
SanctionsKit helps record checks against selected sources. It does not decide which law applies to your activity, and using a bank or another screening provider does not tell you what your own process needs to cover.
List the legal parties in the activity
Make a roster of the parties your approved procedure requires. Give each a role and internal reference. A company and its representative are separate identities, even when they share one account.
For a fictional marketplace, the seller, refund recipient and service provider may be different parties. If another provider performs checks, verify the subjects, source scope and evidence it actually supplies before relying on that work.
Turn the roster into a policy
Use Screening policies to record the purpose, jurisdictions and required or optional sources. Document what is outside the selected coverage. OFAC SDN and non-SDN are separate source choices.
Assign ownership, jurisdiction and activity questions to the responsible team as external checks. Where required, make independent approval part of the case so a completed name comparison cannot silently skip it.
Keep one result for each required identity
In New screening, check each subject and use External reference to connect a saved profile to your roster. Practice in synthetic Sandbox; use authorized Production access and available sources for actual checks.
An API workflow calls POST /api/v1/screenings with the approved policy and one coverage selector. Save the returned ID against the right party. An error for one party cannot inherit another party's no-match result.
Review the complete record at the decision point
In the Review queue, finish candidate findings, outside checks and required approval before recording the business decision. A no-match does not complete ownership, identity verification, AML or cash-reporting work.
Keep the policy version and evidence with the activity. Revisit the roster when parties change, and use monitoring for continuing relationships when required. The requirements guide connects these choices to a working process.
Sources and references
Frequently asked questions
Do OFAC rules apply only to financial institutions?
No. OFAC's explanation covers U.S. persons broadly, with additional program-specific reach. A business should review what it does and which rules apply rather than assume that only banks need a sanctions process.
Does a bank's check cover all parties in my transaction?
You cannot tell from the fact that a bank ran a check. Confirm which identities, sources and activity it covered, and what evidence is available. Compare that scope with your organization's approved procedure.
Should a company and its signatory share one screening result?
They are separate legal parties. If both are in scope, screen each separately and connect their results to the same transaction or account. A company result does not establish that its signatory was checked.
How do I handle a new payment recipient after screening?
Identify the recipient as a distinct party and apply the required check before your policy's decision point. Keep the earlier result for the original party and link the new result to the change.