How to handle an OFAC sanctions match
On a match: block the transaction, preserve records, alert compliance, and file a blocked property report within 10 days.
TL;DR
TL;DR: Do not try to clear or route around the match yourself. Stop the payment, keep the evidence, notify compliance, and report blocked property to OFAC within 10 business days.
The steps in order
- Block the transaction: do not send funds to the flagged counterparty, even if the match looks partial.
- Preserve records: keep the screening result, the counterparty details, and the attempted transaction data.
- Alert compliance: escalate to whoever owns sanctions compliance, including outside counsel if needed.
- File the report: report blocked property to OFAC within 10 days as required for blocked transactions.
Why not to fix it yourself
OFAC applies strict liability, so intent is not required and a misjudged override can still be a violation. Civil penalties start at $356,000 per violation. The safe path is to let the screening result stand, document it, and let a compliance owner decide. SanctionsAI supports this with the dispute_open tool for logging a disputed or false-positive case, while the payment itself stays blocked until a human resolves it.