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To check whether a U.S. sanctions rule applies, identify the people and entities involved, examine ownership and the transaction’s purpose and geography, then check the current Office of Foreign Assets Control (OFAC) programs, lists, exemptions, and licenses. A name-screening result alone cannot settle every case: restrictions may apply because of ownership, a country or sector rule, a blocked person’s interest in property, or the activity itself. Online and digital-currency payments are not exempt.
This is a practical screening sequence, not a legal determination that a particular transaction is permitted. OFAC administers multiple programs with different rules; check the current program regulations and authorization text for the facts at hand.
How to check whether U.S. sanctions apply
Work through these checks before accepting, processing, releasing, or returning funds. Keep a record of the facts reviewed and the decision, especially when a potential match or ownership concern needs investigation.
- Map the transaction and its U.S. connection. Record the customer, counterparty, beneficial owners, beneficiaries, signatories, intermediaries, payment providers, and relevant locations. Note what goods, services, funds, or other property are involved and what each party does. Identify any U.S. person, U.S. business activity, U.S.-based financial institution, or other U.S. jurisdictional connection that may bring the transaction within a program’s reach.
- Identify the potentially relevant sanctions program. Check the current OFAC programs and their regulations for restrictions involving the parties’ locations, the activity, or the property. There is no single country list or name-search result that resolves every sanctions question; restrictions may target particular people, governments, sectors, services, or transactions.
- Screen relevant names against current OFAC lists. Screen the parties and other relevant names using current official list information and your organization’s documented procedures. Treat a possible match as a lead to investigate, not as an automatic final answer. Compare identifying details and transaction context. OFAC says it does not confirm potential matches or false positives for organizations.
- Check direct and indirect ownership. Determine whether any blocked person owns an interest in an entity, including through intermediate entities. Under OFAC’s 50 Percent Rule, an entity is treated as blocked if one or more blocked persons own, directly or indirectly, 50 percent or more of it in aggregate. The entity may be blocked even if its own name does not appear on the SDN List.
- Assess the activity, geography, and payment details. A restriction may apply even if no named-list match is found. Review where the parties and services are located, what the payment is for, and which intermediaries and payment rails handle it. For online or digital-currency transactions, assess the information available about end users as well as direct customers when relevant to the service.
- Check for an exemption or authorization. Determine whether an exemption applies or whether the transaction is authorized by a general or specific license under the relevant program. Follow every condition and limit in the applicable text; do not treat a license as permission for activity beyond its scope.
- Choose the required action and document it. If a sanctions rule requires blocking, freeze the property and follow the applicable blocked-account requirements. If the activity is prohibited but there is no property interest to block, the transaction may instead need to be rejected or stopped. Record the facts, investigation, decision, and action taken.
What a list match does—and does not—tell you
A potential match requires investigation under your own procedures. Compare available identifiers such as names, addresses, locations, dates or other identifying details, and assess whether the transaction facts fit. OFAC FAQ 5, updated September 9, 2026, says organizations should preserve complete records of the investigation and decision and make a risk-based determination. OFAC does not confirm potential matches or false positives for a company.
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A possible match is not the only way a restriction can apply. An entity may be blocked through the 50 Percent Rule even if its name is absent from the list. A country or sector restriction may prohibit particular activity without a named SDN being involved. Conversely, a name resemblance alone does not establish that a person is the listed party. Resolve the facts against the applicable program before deciding what to do.
How ownership can change the result
The 50 Percent Rule is based on ownership, not merely control. If one or more blocked persons own at least 50 percent of an entity in aggregate, directly or indirectly, OFAC treats that entity as blocked. Add blocked owners’ shares together; an entity can meet the threshold through ownership chains involving intermediate entities that also meet the rule.
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Control alone, without at least 50 percent aggregate ownership, does not automatically block an entity under this rule. That is not a blanket safe harbor: dealing directly with a blocked person may still be prohibited, and a program may separately cover certain governments or classes of people. OFAC urges caution where a blocked person has significant minority ownership or control.
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Online payments and digital currency still require sanctions checks
OFAC’s FAQ 560 says obligations for digital currency are the same as for fiat currency. A merchant, payment processor, or other firm facilitating online commerce must not process unauthorized dealings simply because a payment is remote, fast, or digital.
OFAC’s internet remittance guidance, published April 13, 2004, describes the challenges of remote onboarding and customer anonymity. It says IP-address blocking does not fully address risk because IP geography can be dynamic. The guidance recommends authentic customer identification before account opening or transactions and recording payment purpose to improve screening. It also says a company cannot rely on another firm’s compliance program to mitigate its own risk. Apply this older internet-specific guidance alongside current program rules and a risk assessment suited to your service.
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For virtual-currency businesses, OFAC’s industry guidance recommends a routine, tailored risk assessment covering customers, products, services, supply chains, counterparties, transactions, and locations. The parties to assess depend on what information and service the business handles. OFAC’s guidance illustrates this with a payment provider that screened merchant customers but failed to screen available information about end users buying through its platform.
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Blocking and rejecting are different actions
When a sanctions restriction applies, determine whether the facts require blocking property or rejecting a prohibited transaction. In general, blocking means freezing property in which a blocked person has an interest; rejecting means declining or stopping a prohibited transaction when there is no property interest requiring a block. The applicable program and facts control, so do not choose between these outcomes solely from a name-screening result.
OFAC FAQ 5, updated September 9, 2026, says sanctions-related blocking and rejection actions must be reported to OFAC within 10 business days. Retain records under the applicable regulatory requirements. Confirm current reporting procedures and recordkeeping rules for the relevant program.
Compare common screening situations
| Situation | What to examine | Why a name search is not enough |
|---|---|---|
| A possible match to a named person | Identifiers, transaction context, the person’s role, any property interest, and applicable authorization. | A possible match must be investigated; OFAC does not resolve company false positives for it. |
| A company partly owned by blocked persons | Each blocked owner’s direct and indirect share, aggregated across owners and ownership chains; also assess control and dealings with blocked persons. | The company may be blocked by operation of the 50 Percent Rule even if it is not named on the SDN List. Control alone does not automatically trigger that rule. |
| A country- or sector-restricted transaction | Locations, activity, goods or services, parties, intermediaries, payment purpose, and any applicable exemption or license. | A restriction can apply without a named SDN match, depending on the program and transaction. |
Build a repeatable decision record
For each review, preserve enough information to explain what was checked and why the transaction proceeded, was blocked, or was rejected. A useful record includes:
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- The transaction date, parties, beneficial ownership information, locations, payment route, and purpose.
- The lists, program regulations, and license or exemption text consulted, with the version or date checked.
- The identifiers and contextual facts used to assess any potential match, plus the reason for the decision.
- The action taken, any required OFAC report, and the records retained under applicable requirements.
OFAC FAQ 560 states: “There is no single compliance program or solution suitable for every circumstance.” The FAQ is dated March 19, 2018; use it as a general principle, alongside current program-specific rules and guidance.
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