Screen SMARTLY: Best Practices for OFAC Screening

Is complacency creeping into your day-to-day screening routine?

You could be missing out on better accuracy and efficiency. For best results, don’t just screen – screen SMARTLY.

Search refinement settings are your friends. If you’re using a restricted party screening software tool you can reduce false positives (who has the time to wade through hundreds of unwanted names?), and also ensure you’re not missing alerts due to typos or names with multiple possible spellings. You can maximize screening efficiency by understanding what various settings do and determining when you should use them and when it would be more efficient to turn them off. Among your options: grammatical variations on a word (like‘s’ or ‘ed’ endings), synonyms of a name, or even matches that simply sound like your searched term.

Mind the three W’s of screening: Who to screen (International customers may be obvious, but what about domestic customers that re-export internationally? What about your employees? Take a good look at all the parties with whom you connect, and make sure nobody is overlooked. ); When to screen (It should be done before signing a contract with a new customer or manufacturer); What to enter in the search fields (When using a software solution, be strategic and select parameters in all possible fields – such as City, State and Company – to assure the quality of matches returned).

Audit recording is essential. You can screen until the cows come home, but in an audit, if there’s no record of your restricted party screening activity it’s as though it never happened. Details about who you screened, when you screened and the result of that screening are integral not only to passing your audit but to avoiding internal oversights and miscommunication. Conscientious day-to-day screening keeps your transactions legal, but don’t neglect your responsibility to prove your due diligence.

Rescreen daily. Once you’ve screened and received the all-clear on your party, it’s tempting to high-five your colleagues and add to your “done” pile. But no screening is ever really “done” so long as you’re still doing business with the individual or company in question. Government watch lists change often – even a longtime employee or customer can suddenly appear as a designated party – and regular rescreening is the only way to know your transactions are compliant each and every time.

Timeliness is everything. You need access to the most current, up-to-date sanctioned and designated party lists or your screening results simply can’t be trusted. Receiving updates as they are published is your best bet.

List selection matters. You may think screening against every list available is wise, but by doing so you’re actually inviting invalid matches. Pare down the number of lists you use by doing some self-examination of your industry, where your customers are located, and the products you export. If, for example, your company does not deal with government contracts of any kind, screening against the General Services Administration (GSA) List is unnecessary.

Your escalation process. Smart screeners have an incident management plan in place for when OFAC screening yields a match. They ensure decision-makers receive all the details required to investigate and clear transactions with minimal delay (postponing lawful shipments won’t endear you to impatient customers) or, if there’s a true threat of violation, immediately stopping the transaction. Many companies use email alerts as a reliable communication channel to keep the right people in-the-know. Thoroughly detailed notes regarding your incident response activities are a must so that facts are clear and decisions are defensible in case of an audit.

Solid compliance programs demand smart screening. How does your current process measure up?