OFAC & Sanctions Screening

OFAC & Sanctions Screening is the gate at the front of the grant lifecycle: you screen a prospective grantee — and its principals and jurisdiction — against the OFAC sanctions lists, and record a due-diligence summary, before the board can decide on the grant. A non-clear result must be dispositioned and will gate the grant. Reach it from Grant Compliance (step 2), or its Open card on the overview.

Setting up the screen

Choose the Grantee organization and enter its Country. Then build the list of screening targets — everyone and everything that should be checked:

  • The organization itself.
  • Its directors, officers, and key employees (including those paid from grant funds).
  • Beneficial owners where ownership information is available.

For each target, set its Type and list any name variants — aliases and transliterations — separated by commas. Foreign names should be screened in both their original-language and romanized forms. Use + Add target to add rows.

Running the screen and dispositioning results

Click Run screening. Each target comes back either with no list matches or with one or more potential matches, each showing the matched name, the list it came from, a match score, and any sanctions programs. For every target, choose a Disposition; any result other than clear requires a disposition note explaining how you ruled the match in or out.

An overall result banner summarizes the screen:

  • Clear — no true matches; you may proceed to board review.
  • Escalated — a potential match needs further due diligence to resolve before any decision.
  • Blocked — a confirmed match: stop, do not transact, and follow your escalation and counsel process.

When every target is dispositioned, click Finalize screening record. The record captures the result, the date, and the list version screened against, so it is reproducible later.

Due diligence ("know your grantee")

Below the screen, record a risk-based due-diligence summary. You can use the Non-profit registry lookup to search the IRS/ProPublica registry, verify the grantee, and add the match to your findings. Enter a Summary of vetting findings and a Risk rating (low / medium / high), then click Record due diligence.

Both the screening record and the due-diligence record are prerequisites the Board Review & Approval form requires before a new grant can be decided.

Re-screening

Screening is point-in-time. Re-run it at each annual review, and whenever something changes (a new director or officer, a change of control, or a change in country of operation). OFAC lists change frequently, so a prior clear result does not carry forward on its own. A new screen creates a new record; the prior one is kept as superseded.