OFAC Source

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1. OFAC: The US Department of the Treasury’s Office of Foreign Asset Control (OFAC) publishes a sanctions list which requires specific action(s) under US regulations, including but not limited to freezing assets, rejecting transactions and/or reporting potential matches to OFAC for instruction and follow-up. OFAC has a ten day reporting requirement for matches determined to be true or exact matches to the entities on the SDN or Non-SDN lists. Lists covered under this category in the LexisNexis search are:

For more information about OFAC, please refer to the section “An Explanation about OFAC” at the end of this document.

The LexisNexis OFAC SDN (specially designated nationals) screening list contains entities that are subject to economic sanctions programs administered by OFAC. This screening list includes individuals and organizations associated with such activities as narcotics trafficking, terrorism, democratic opposition, and weapons proliferation. LexisNexis obtains information for this screening list from the OFAC SDN list, which includes thousands of individuals, companies, organizations, shipping vessels, and banks. The LexisNexis OFAC SDN screening list also includes unique vessel owner records where OFAC has indicated a particular vessel has an owner.

OFAC publishes a list of foreign individuals and entities determined to have violated, attempted to violate, conspired to violate, or caused a violation of U.S. sanctions on Syria or Iran. It also lists foreign persons who have facilitated deceptive transactions for or on behalf of persons subject to U.S. sanctions. Collectively, such individuals and companies are called "Foreign Sanctions Evaders" or "FSEs." Transactions by U.S. persons or within the United States involving FSEs are prohibited.

The FSE List is not part of the Specially Designated Nationals (SDN) List. However, individuals and companies on the FSE List may also appear on the SDN List.

OFAC publishes a list of to identify person operating in sectors of the Russian economy identified by the Secretary of the Treasury pursuant to Executive Order 13662. Directives found within the list describe prohibitions on dealings with the persons identified.

The SSI List is not part of the Specially Designated Nationals (SDN) List. However, individuals and companies on the SSI List may also appear on the SDN List.

This is a list of entities represented by members of the Palestinian Legislative Council (PLC) who were elected to the PLC on the party slate of Hamas, or any other Foreign Terrorist Organization (FTO), Specially Designated Terrorist (SDT), or Specially Designated Global Terrorist (SDGT), provided that any such individuals are not named on OFAC's list of Specially Designated Nationals and Blocked Persons (SDN List).

OFAC has developed a list of foreign financial Institutions that are subject to sanctions under the following laws and orders: Certain provisions of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA), the National Defense Authorization Act of Fiscal Year 2012 (NDAA), the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) and certain executive orders.

On October 9, 2012, the President signed Executive Order (E.O.) 13628, which provides for, among other things, the implementation of certain sanctions set forth in the Iran Threat Reduction and Syria Human Rights Act of 2012 (TRA). Section 1 of E.O. 13628 provides that the Secretary of the Treasury, pursuant to authority under the International Emergency Economic Powers Act (IEEPA), shall take action to implement certain sanctions set forth in Section 6 of the Iran Sanctions Act of 1996, as amended (ISA), when the President, the Secretary of State, or the Secretary of the Treasury imposes such sanctions on a person pursuant to provisions of ISA, the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, as amended, or the TRA. Section 6 of ISA includes both blocking and non-blocking sanctions.

In order to implement the non-blocking provisions of Section 6 of ISA, OFAC developed the NS-ISA List.

These entities are identified by OFAC as meeting the definition of the term Government of Iran or the term Iranian financial institution as set forth in, respectively, sections 560.304 and 560.324 of the ITSR and pursuant to Executive Order 13599.

2. Global Sanctions List: These lists are compiled from various domestic and foreign sources and contain various types of sanctioned entities. Please consult your financial institution’s risk- based policies or your general counsel for matches found on this list.

• Australia Department of Foreign Affairs and Foreign Trade (DFAT) -- Australia enacted a charter in response to a UN resolution following the September 11, 2001, terrorist attacks on the United States. Australia's charter includes entities listed in the UN Consolidated List, plus unique entities designated by Australia's Minister for Foreign Affairs. The consolidated list of entities is maintained by Australia's Department of Foreign Affairs and Trade (DFAT), which is active in Asia-Pacific and other worldwide efforts to counter terrorism. Australia passed legislation making it a criminal offense to give, use, or deal with funds, other financial assets, and economic resources owned or controlled by entities on this list.

• Commodity Futures Trading Commission List of Regulatory and Self-Regulatory Authorities -- Includes disciplinary information for all current and former Commodity Futures Trading Commission (CFTC) registrants. It has name, business address and futures registration history, details about disciplinary actions taken by NFA, the CFTC and all of the U.S. futures exchanges.

• Defense Trade Controls (DTC) Debarred Parties -- The U.S. Department of State maintains lists of persons who are not allowed to participate, either directly or indirectly, in any transaction that requires a State Department license or State Department approval. LexisNexis consolidates these lists into a single List of Debarred Parties. Typically, if a transaction involves the export of articles used in defense, defense services, or technical data related to defense articles or services, the transaction would require an export license. Individuals and companies found on the List of Debarred Parties are sanctioned by the U.S. government and may not export goods from the United States or receive exported goods from the United States.

• European Union Designated Terrorists –- This is also named the EU Consolidated list. A consolidated list of entities subject to European Union (EU) financial sanctions was developed and is maintained for the European Commission by the European Banking Federation, the European Savings Banks Groups, the European Association of Co-operative Banks, and the European Association of Public Banks. All persons and entities doing business in the EU, including non-EU citizens and businesses established in the EU but doing business outside the EU, are required to freeze all funds and economic resources of entities on the list, and are prohibited from making funds or economic resources available.

• FATF Financial Actions Task Force Deficient Jurisdictions -- The FATF Financial Action Task Force screening list is used by firms to help identify locations that may pose a higher risk of money laundering or terrorist financing. Financial Action Task Force (FATF) is the global standard setting body for anti-money laundering and combating the financing of terrorism (AML/CFT). To protect the international financial system from money laundering and terrorist financing risks, and to encourage greater compliance with AML/CFT standards, the FATF identified jurisdictions that have strategic deficiencies. Along with the FATF-style regional bodies, FATF works with jurisdictions to address those deficiencies that pose a risk to the international financial system. Most regulators agree that an institution should understand and evaluate the specific risks associated with doing business in, opening accounts for customers from, or facilitating transactions involving these locations.

Federal Bureau of Investigations (FBI) Lists: Complete information for each FBI list is below. Companies are advised to contact their district FBI office for compliance requirements and follow-up.

• FBI Hijack Suspects -- The LexisNexis Federal Bureau of Investigation (FBI) Hijack Suspects screening list contains all information currently available for each suspect of the September 11, 2001, terrorists attack.

• FBI Seeking Information -- The Seeking Information list contains photographs and other descriptive information about persons the FBI believes may be involved in terrorist activities or may be able to help locate those involved in terrorist activities.

• FBI Most Wanted Terrorists --The Most Wanted Terrorists list contains information on alleged terrorists who have been indicted by U.S. federal grand juries.

• FBI Most Wanted -- The LexisNexis FBI Most Wanted screening list contains the FBI's Featured Fugitives and FBI's Crime Alerts. The featured fugitives are grouped according to crime categories, Crimes Against Children, Criminal Enterprise Investigations, Cyber Crimes, Domestic Terrorism, Violent Crimes, and White Collar Crimes. The screening list includes detailed descriptions of the fugitives.

• FBI Top Ten Most Wanted -- The Top Ten Most Wanted list contains information on the top 10 fugitives wanted by the FBI.

• Her Majesty’s Treasury’s Consolidated List of Financial Sanctions Targets (formerly known as Bank of England Consolidated Sanctions) -- This list is a consolidated list of targets identified by the United Nations (UN), European Union (EU), and UK. This list may include criminals such as those involved in terrorism, proliferation of WMD, or activities relating to targeted state regimes.

• Hong Kong Monetary Authority (HKMA) -- The Hong Kong Monetary Authority (HKMA) is the government authority in Hong Kong responsible for maintaining monetary and banking stability. One of its main functions is to promote the safety of Hong Kong's banking system through the regulation of banking business and the supervision of authorized institutions. To give effect to UN resolutions that prohibit the making of funds available to designated terrorists, a list of designated terrorists is published in the Gazette.

• Monetary Authority of Singapore (MAS) -- The Monetary Authority of Singapore (MAS) is the government agency responsible for the regulation of all monetary policy, banking functions, and financial services in Singapore. The MAS requires banks and financial institutions incorporated in Singapore, or incorporated outside of Singapore but located in Singapore, to institute rigorous measures to guard against money-laundering and terrorist financing. The MAS list of designated entities and individuals is known as the Schedule. The MAS Act regulates dealings in property and assets for entities and individuals on the Schedule.

• Office of Controller of Currency - Unauthorized Banks -- This list is compiled from data regarding unauthorized banks provided by the Office of the Comptroller of the Currency.

• Offshore Financial Centers (OFC) -- The 2007 Federal Financial Institutions Examination Council (FFIEC) Bank Secrecy Act/Anti-Money Laundering Examination Manual recommends that financial institutions consider offshore financial centers (OFC) in their risk analyses, specifically as they regard geographical risk. Generally speaking, OFCs are believed to present additional risk because history has shown a higher potential for involvement in money laundering or other financial corruption and fraud. LexisNexis gathers information for the Offshore Financial Centers screening list from International Monetary Fund (IMF), particularly the IMF Staff Assessments and the OFC Assessment Program progress reports. To provide better risk management coverage, major cities and/or ports within these jurisdictions may also be included in the screening list.

• OSFI – Canada -- Our OSFI Consolidated List—Canada contains entities subject to financial sanctions administered by the Office of the Superintendent of Financial Institutions (OSFI) in Canada. OSFI supervises and regulates Canadian financial institutions. We compile this watchlist to help institutions comply with specific regulatory measures in Canada. The entities contained in the OSFI Consolidated List - Canada are associated with restrictions involving Al Qaida; the Taliban; the suppression of terrorism; special economic measures against Burma; or the Regulations Implementing the United Nations Resolution on Iran (RIUNRI).

• OSFI Sanctioned Countries – Canada -- The OSFI Country watchlist contains jurisdictions or countries subject to financial sanctions or economic measures administered by the Office of the Superintendent of Financial Institutions (OSFI) in Canada. OSFI supervises and regulates Canadian financial institutions. This list was added in response to Canada's Special Economic Measures (Burma) Regulations.

• Primary Money Laundering Concern (PMLC) Entities -- Section 311 of the USA PATRIOT Act21 grants the Secretary of the Treasury, after consulting other agencies and considering specific factors, to conclude that an entity is a PMLC (primary money laundering concern). The LexisNexis Primary Money Laundering Concern screening list contains the names of designated organizations.

• Primary Money Laundering Concern (PMLC) Jurisdictions -- The LexisNexis PMLC-Jurisdictions screening list contains the names of designated jurisdictions.

• State Department Terrorist Exclusions -- The Terrorist Exclusion List (TEL) was created within section 411 of the USA PATRIOT Act and authorizes the Secretary of State to designate terrorist organizations for immigration purposes. Foreign persons who provide support or are otherwise associated with a TEL organization may be refused entry into or may be deported from the United States, thus they are “excluded” from U.S. soil.

• United Nations Named Terrorists -– This is also named the UN Consolidated list. United Nations Resolution 1267 established the Security Council Committee, which oversees sanctions imposed on individuals and entities belonging or related to the Taliban, Usama Bin Laden, and the Al-Qaida organization. The Security Council Committee maintains a list of individuals and entities called the United Nations Consolidated List.

• US Bureau of Industry and Security (BIS) -- Our Bureau of Industry and Security watchlist is a compilation of several lists published by the Bureau of Industry and Security (BIS). Formerly known as the Bureau of Export Administration, BIS is located within the U.S. Department of Commerce. Entities may be designated to any of the lists through actions taken by the Department of Commerce. The first component is the BIS Denied Persons list, which includes individuals and entities that have been denied export privileges. Because they have been denied export privileges, you are prohibited proceeding with any transaction that will violate the terms of the denial order. The BIS Unverified List includes parties deemed suspect because BIS has been unable to verify end use for previous transactions, providing a “red flag” that should be resolved before proceeding with the transaction. The third component is the BIS Entity List, which contains parties whose presence in a transaction can trigger a license requirement under the Export Administration Regulations. The license requirements that apply to each listed party are contained in the list. These requirements must be met before proceeding with any transaction. You are encouraged to contact one of the BIS Export Enforcement offices. if you are asked to participate in a transaction that you believe may be a violation of the Export Administration Regulations.

• World Bank Ineligible Firms -- The World Bank maintains a list of individuals and firms with which it refuses to do business because they were found to have violated the fraud and corruption provisions of the World Bank's Procurement Guidelines or Consultants Guidelines.

NOTE: International Police Most Wanted and Red Alerts - This list is no longer available, as Interpol changed their Interpol policies in June 2013, limiting access to their full data download to registered law enforcement agencies only.

3. Foreign Affiliation: These two types of list contain the names of individuals or entities with ties to or interests in non-U.S. countries. The lists are primarily used to uncover entities with foreign ties since international exposure, in general, raises an institution’s money laundering risk. These lists are NOT composed of criminals, terrorists or those subject to sanction lists. It is a geography risk identification tool, and as such, carries no reporting requirements. Consult your organization’s risk-based anti-money laundering policies or your general counsel for matches found against these lists.

• Chiefs of State and Foreign Cabinet Members -- As part of the USA PATRIOT Act's required special due diligence, organizations must conduct enhanced scrutiny of accounts maintained by politically exposed persons with demonstration of this enhanced scrutiny readily available. This cumulative list is compiled from the CIA's online directory of Chiefs of State and Cabinet Members of Foreign Governments. When the screening list is updated, names are not removed when they are removed from the CIA’s online directory, but, instead, they are labeled as formerly holding their respective government position. The screening list contains current and former government officials.

• Foreign Agent Registrations -- This database is comprised of entities that have registered under the Foreign Agents Registration Act, originally passed in 1938. The act requires people and organizations who are under foreign control ("agents of a foreign principal") to register with the Department of Justice when acting on behalf of foreign interests. This law defines the agent of a foreign principal as someone who:

1. Engages in political activities for or in the interests of a foreign principal;

3. Solicits or dispenses anything of value within the United States for a foreign principal;

4. Represents the interests of a foreign principal before any agency or official of the U.S. government.

The Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury administers and enforces economic and trade sanctions against targeted foreign countries, terrorism sponsoring organizations and international narcotics traffickers based on U.S. foreign policy and national security goals. OFAC acts under Presidential wartime and national emergency powers, as well as authority granted by specific legislation, to impose controls on transactions and freeze foreign assets under U.S. jurisdiction. Many of the sanctions are based on United Nations and other international mandates, are multilateral in scope, and involve close cooperation with allied governments.

The Office of Foreign Assets Control ("OFAC") file is designed to assist the public in complying with the various sanctions programs administered by OFAC. In addition to the OFAC content, scans against other global watch lists such as the FBI Fugitives including 10 Most Wanted, Most Wanted Terrorist, United Nations Sanctions list, World Bank Debarred Firms list, Politically Exposed Persons (from the Chiefs of State and Cabinet Members of Foreign Governments), and the Commodity Futures Trading Commission.), Office of Comptroller of Currency list of Unauthorized Banks, and Interpol European Union Most Wanted (Recent Event Red Alerts), HM Treasury’s Consolidated List of Financial Sanctions Targets (formerly known as Bank of England Consolidated list.

New Federal Register notices with regard to Specially Designated Nationals or blocked entities may be published at any time. Entities and individuals identified are occasionally licensed by OFAC to transact business with U.S. persons in anticipation of removal from the list or because of foreign policy considerations in unique circumstances. Licensing in anticipation of official Federal Register publication of a notice of removal based on the unblocking of an entity's or individual's property is reflected in this publication by removal from the list.

OFAC SDN, OFAC Non-SDN and additional US & International Lists of Security Risks Source