OFAC screening means checking every party to an export against the U.S. Treasury's sanctions lists, above all the Specially Designated Nationals and Blocked Persons (SDN) List. Most exporters run it together with the Commerce and State Department restricted-party lists.
Classification tells you what you are exporting; screening tells you who you are exporting to. A correctly classified EAR99 item shipped to a blocked person is still a violation. For how the sanctions programmes themselves work, see OFAC sanctions explained.
Which lists should exporters screen against?
| Source | Lists | What they cover |
|---|---|---|
| Treasury (OFAC) | Specially Designated Nationals and Blocked Persons (SDN) List | Individuals and entities whose property is blocked. U.S. persons generally may not deal with them. |
| Treasury (OFAC) | Non-SDN lists (the Consolidated Sanctions List) | Sectoral sanctions and other programme-specific lists. |
| Commerce (BIS) | Entity List, Denied Persons List, Unverified List, Military End-User List | Part 744 and Part 764 of the EAR. |
| State Department | For example ITAR debarred parties and nonproliferation sanctions | Debarred and sanctioned parties. |
The U.S. government publishes the Consolidated Screening List (CSL), which combines many of these lists in one searchable file. At a minimum, screen against the CSL and OFAC's lists. For what the CSL contains and how to search it, see how to use the Consolidated Screening List.
Who to screen
Screen every party to the transaction:
- the buyer and the ultimate consignee;
- the end user, if different;
- intermediate consignees, agents and freight forwarders;
- banks and payment parties where your process covers them;
- the owners of entity customers, where ownership may make them blocked.
A common gap is screening the buyer and stopping there, with the end user and the forwarder never checked.
What is the OFAC 50 percent rule?
Under OFAC guidance, an entity owned 50 percent or more, directly or indirectly, individually or in aggregate, by one or more blocked persons is itself blocked, even if its name appears on no list. Screening names alone can miss them. For higher-risk customers, collect ownership information and screen the owners too. See how SDN entries and blocking work.
Exact matches, fuzzy matches and false positives
Names are transliterated, abbreviated and misspelled, so good screening looks beyond exact matches. The cost is more false positives. A sound review has four steps:
- Run the name and any aliases against the lists.
- Compare each potential match with the details in the list entry: address, country, date of birth, identification numbers.
- Clear it with a documented reason, or escalate it.
- Never proceed on an unresolved match.
Decide in advance how fuzzy the matching should be, who reviews potential matches, who can clear one, and when legal advice is needed. Clearing a match without recording why is a common mistake.
When to screen
Screen at customer onboarding, at order entry, before each shipment is released, and whenever a customer's details change. Lists change, sometimes daily, so a customer screened once at onboarding and never again can become a listed party without anyone noticing. Use current list files too. A screen against a list that is weeks old is not a screen.
What to do with a true match
Stop. Do not ship and do not release technology. For SDN matches, consider whether property must be blocked and reported to OFAC, and take legal advice. For Entity List parties, the entry's licence requirement and review policy decide whether a licence can even be sought. See what an Entity List listing means.
Screening records
Keep a record of each screen: the date, the lists and versions used, the result, and how any potential match was resolved. EAR records are generally kept for five years under Part 762 (see export recordkeeping requirements). OFAC has its own recordkeeping rule, which since March 2025 generally requires records to be kept for ten years.
Testing your screening process
Once the lists, screening points, matching rules, escalation path and records are settled, test it. Every so often, screen names you know are listed and confirm that the process catches them.
Screening and classification together
Screening and classification answer different questions, and an export needs both. Whether a shipment needs a licence depends on the ECCN, the destination, the end use and the end user. See when an export licence is required and why EAR99 items still need screening. Screening is also part of the BIS eight elements of an export compliance program.
Screening in ECCN.help
ECCN.help screens names against the OFAC SDN and consolidated sanctions lists, which it refreshes weekly. If the lists are older than the set threshold, screening does not run, so it never returns a "clear" result based on stale lists. You can start a screen from any classification in the ECCN.help Classification Workflow, and screening is free to use.
ECCN.help provides research and assistance, not legal advice. Verify every result against the regulation.