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For a U.S.-connected transaction, screen the supplier’s exact legal identity in OFAC’s official Sanctions List Search, investigate possible matches, check whether blocked persons own 50 percent or more of it in aggregate, and assess the rules that apply to the particular transaction. A name search is only an initial screen—not a clearance or a complete sanctions analysis.
First, establish which Korea the supplier is connected to
“Korean supplier” does not identify a jurisdiction. Confirm whether the company is registered or operating in the Republic of Korea (South Korea) or the Democratic People’s Republic of Korea (North Korea), and verify its actual registration and operating locations. Do not infer the applicable restrictions from the word “Korean” alone. The relevant sanctions rules depend on the parties, jurisdictions, goods or services, and transaction facts.
Run an initial search in OFAC’s official tool
- Identify the company accurately. Collect its exact registered legal name, local-language name, known Romanizations and aliases, country of registration, address, and registration number if available. Gather relevant ownership information as well. These details help distinguish the supplier from another party with a similar name.
- Search the OFAC Sanctions List Search. Use the official tool for an initial manual screen. It searches potential matches on the Specially Designated Nationals (SDN) List and consolidated non-SDN lists. OFAC also provides current list data for download through its Sanctions List Service.
- Search name variants. Try alternate spellings, transliterations, aliases, and relevant identifying details. A search that uses only one Romanized spelling can miss a potential listing or produce an incomplete picture.
The SDN List concerns blocked persons. Non-SDN lists can impose different, program-specific restrictions; a result on one of those lists is not automatically equivalent to an SDN blocking designation. Check what the applicable list and sanctions program actually require.
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OFAC’s search uses fuzzy logic to surface potential name matches. Its score is a similarity aid, not a legal determination that the supplier is the listed party. A similar name by itself is not enough to establish identity.
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Compare the potential match with the supplier’s identifiers, including its address, country, aliases, registration details, and other available identifying information. Document why the result is a match or why it can be ruled out. OFAC does not set one universal match threshold for every case; organizations need screening procedures suited to their circumstances. If the identity remains uncertain, pause the transaction for compliance or legal review rather than treating an ambiguous result as either a confirmed match or a clean screen.
Check ownership even if the supplier is not listed
Under OFAC’s general 50 Percent Rule, an entity is blocked if one or more blocked persons own, directly or indirectly, 50 percent or more of it in aggregate—even when the entity is not separately named on the SDN List. OFAC FAQ 91, updated August 21, 2024, explains that the entity’s property and interests in property are blocked regardless of whether the entity itself appears on the SDN List.
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Trace the supplier’s ownership through intermediate entities and identify blocked owners whose interests must be aggregated. Do not stop at the supplier’s direct shareholders or at the result of a list search on the supplier’s own name.
OFAC FAQ 398, dated August 11, 2020, states: “OFAC’s 50 Percent Rule speaks only to ownership and not to control.” Control without 50 percent ownership does not, by itself, automatically block an entity under this rule. Control or other facts can nevertheless create risk or be relevant to a separate designation or another applicable restriction.
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Assess the rules for the actual transaction
A list result is not the whole sanctions analysis. Establish the transaction’s U.S. nexus and identify the parties, intermediaries, relevant jurisdictions, and goods or services. Then check the current regulations, guidance for the relevant program, and any applicable authorization or exemption. Different OFAC programs can impose different restrictions, and some lists are non-blocking.
U.S. persons generally must comply with applicable U.S. sanctions wherever they are located. Certain foreign persons and transactions can also be covered, depending on the program and facts. If the supplier has North Korea-related connections, ownership is unclear, a potential match cannot be resolved, or the U.S. nexus is complex, review the current rules with qualified sanctions counsel or a compliance professional. These steps do not determine whether a particular supplier or transaction is permitted.
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Keep a record and screen again when it matters
Retain enough information for another reviewer to understand what was checked and why the result was accepted, escalated, or ruled out. A useful record includes:
- The screening date and the list data or version used.
- The exact legal name, aliases, transliterations, and other variants searched.
- The identifying information reviewed and the disposition of each potential hit.
- The ownership evidence reviewed, including the rationale for the conclusion.
- The transaction facts and applicable program rules considered.
Repeat screening at appropriate points, such as supplier onboarding and before material transactions, and when ownership, identifying details, or sanctions information changes. OFAC identifies stale lists and failure to account for alternative spellings as weaknesses in screening systems. Recheck current OFAC lists and guidance immediately before relying on a result.
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Choose a screening method that fits your volume and risk
For an occasional initial check, OFAC’s public search tool is a practical starting point. OFAC also makes list data available for download. Organizations screening many counterparties may consider commercial screening software, but OFAC does not endorse a particular vendor. Compare methods against the needs of your process:
| Consideration | Manual official search | Downloaded lists or commercial software |
|---|---|---|
| List coverage | OFAC Sanctions List Search covers potential matches on the SDN List and consolidated non-SDN lists. | Check which lists and jurisdictions the selected data or product covers; coverage is not established for every tool. |
| Updates | Recheck the current public search when screening. | Confirm update handling and how current the data is; do not assume an update schedule. |
| Names and ownership | Search relevant variants and investigate ownership separately. | Check support for aliases, transliterations, ownership depth, and investigation of possible matches. |
| Workflow and records | Keep a dated record of searches and decisions. | Assess audit-trail and review features, and whether they fit the organization’s transaction volume and risk. |
Whatever method is used, a potential hit still needs review against identifying details, ownership, and the rules for the transaction.
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