What does OFAC stand for?
OFAC stands for Office of Foreign Assets Control and is an agency of the US Department of the Treasury.
What is the OFAC sanctions list?
OFAC administers various programmes. The best-known list is the SDN List, which can contain individuals, companies, organisations and other entities.
Why does OFAC affect Swiss companies?
Points of contact arise in particular through US dollar payments, international banks, American business partners and global supply chains.
What information does an entry contain?
Depending on the data set, entries can contain names, aliases, dates of birth, nationalities, addresses, programmes and reference numbers.
Hits and false positives
A hit is not a confirmation. Similar names, different spellings and transliteration lead to false alarms.
Is OFAC enough on its own?
For Swiss companies, SECO, UK and UN are often taken into account as well; see SECO, UK and UN. Where there is an EU connection, the EU sanctions list can also be relevant.
When and whom to screen?
Before customer, supplier and international business relationships and during periodic reviews. Beneficial owners and controlling persons can also be relevant. The process of a screening is explained in the article What Is Sanctions Screening?
Documentation
The time of the check, the source, the search term, the result and the reasons for ruling out a match should be documented.
Conclusion
OFAC is an important source of information outside the United States as well. The specific legal relevance depends on the connection in question and on the business model.