Bermuda’s Sanctions List in the Spotlight: Understanding OFAC’s SDN List and Search Tool
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The Office of Foreign Assets Control (OFAC) maintains a comprehensive sanctions list, known as the Specially Designated Nationals and Blocked Persons list, or SDN List. This list is regularly updated to include individuals and entities subject to various economic sanctions imposed by the US government.
Other Sanctions Lists Maintained by OFAC
- Foreign Sanctions Evaders List
- Non-SDN Iran Sanctions Act List
- Sectoral Sanctions Identifications List
- List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions
- Non-SDN Palestinian Legislative Council List
The Search Tool: Facilitating Searches for Specific Entities
OFAC has developed a powerful search tool that uses approximate string matching to identify potential matches. The tool allows users to set a threshold, or confidence rating, for the closeness of any potential match returned in their search results.
Important Considerations
- Pay close attention to the program codes associated with each returned record, as these codes indicate how a true hit should be treated.
- While the search tool can detect certain misspellings and return near-matches based on the user-set confidence rating, it is not a substitute for thorough due diligence.
Use of the Sanctions List Search Tool
OFAC explicitly advises that use of the Sanctions List Search tool does not limit any criminal or civil liability for acts undertaken as a result of, or in reliance on, such use. Rather, it is one tool offered to assist users in utilizing the SDN List and other sanctions lists, and should be used in conjunction with appropriate due diligence procedures.
Compliance Requirements
Financial institutions and businesses operating in Bermuda are advised to familiarize themselves with OFAC’s sanctions lists and search tools to ensure compliance with all relevant regulations and laws.