Shipping & Trade OFAC Compliance Checklist
Sanctions screening controls for shipping, freight, and international trade companies.
Counterparty screening
- Screen every shipper, consignee, and notify party
- Vessel and IMO number screening
- Port of loading and discharge screening
- Beneficial owner screening
Cargo screening
- Commodity classification vs dual-use lists
- End-use and end-user verification
- Transshipment risk assessment
- Denied-party list screening (BIS, OFAC, EU)
Documentation
- Screening records retained 5 years
- Audit trail for every clearance decision
- Officer sign-off on high-risk shipments
Why this checklist exists
This checklist was built for teams handling OFAC screening API. Each item addresses a common failure mode we've seen in real workflows. Skipping a step doesn't save time — it creates rework, disputes, or missed signals downstream.
Related resources
1. Screen consignee and end-user against SDN
Before shipping goods internationally, verify the consignee, end-user, and any intermediaries against the OFAC SDN list. A shipment routed through a non-sanctioned intermediary to a sanctioned end-user is still a violation. Screen every party in the transaction chain.
2. Verify destination country
OFAC maintains comprehensive embargoes on 16 jurisdictions. Even if the consignee is clean, shipping to an embargoed country is prohibited regardless of the end-user. Check the destination country against the current embargoed jurisdiction list before accepting any order.
3. Screen vessel and carrier
OFAC has sanctioned specific vessels, shipping companies, and carriers. Before booking freight, screen the vessel IMO number and carrier name against the SDN list. A clean consignee on a sanctioned vessel is still a violation.
4. Document your screening process
Maintain records of every screening check: who was screened, when, against which list version, and the result. In a customs audit or OFAC inquiry, these records are your defense. Electronic logs with timestamps are preferred over paper.
5. Re-screen before each shipment
The SDN list updates daily. A counterparty clean last month may be sanctioned today. Never rely on a one-time screening at account opening — screen before every shipment. Automated API-based screening (like SanctionsAI) makes this practical at scale.