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The
Patriot Act, OFAC and the Specially Designated
Nationals List
What
should I do if there is the name of a
potential customer appears to be a match with
the SDN list?
If
the match is to the SDN list, you may need to call
OFAC on their hotline at 1-800-540-6322.
However, some “hits” or “matches”
that appear on credit reports or other reports
provided by vendors to dealers might indicate that
the person or entity’s name is on another list,
such as the Denied Persons List or the FBI’s
Most Wanted List.
OFAC
recommends that prior to calling their hotline,
the following “due diligence” steps be taken:
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Determine
if the match is against the SDN list.
In order to do this, you may need to
contact your software provider.
If the match is against another list,
contact the “Keeper” of that list.
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Once
you determine that the match is against the
SDN list, evaluate the quality of the hit.
Compare the name of the person involved
in your potential transaction with the name on
the SDN list.
If your transaction is with an
individual, but the SDN list is with a company
or organization, or if only a partial match of
the person’s name has occurred, OFAC does
not require that you contact their hotline.
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OFAC
also recommends that you compare the detailed
information on the SDN list with information
in your possession.
The SDN list often includes the
person’s full name, address, nationality,
passport, tax ID number, birth date and
aliases. If
your potential customer’s full name is a
match, and you do not have any of this
information for comparison purposes, you
should request additional information and make
this comparison.
After comparing information, you may
find that your potential customer is not a
Specially Designated National.
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If
you compare information and believe that your
potential customer is the SDN listed on
OFAC’s list, call the OFAC hotline at
1-800-540-6322.
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