Sanctions Screening
Sanctions screening is the process of checking counterparties — customers, suppliers, freight forwarders, banks, beneficial owners — against OFAC's SDN list and other global sanctions lists before a transaction occurs. Screening once at onboarding isn't enough. OFAC adds names without notice, and a counterparty clean at contract signing can be designated before delivery. We've seen export managers running weekly batch screens on a Tuesday cut list miss a Thursday afternoon SDN addition that cleared a Friday shipment. The OFAC standard is reasonable care, but "reasonable" in an enforcement context means documented, systematic, and frequent enough that new designations are caught before goods or funds move.
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