SDN Hits - OFAC

Here’s the Treasury guidance on clearing SDN and OFAC hits:

When the "hit" is a common name, we can recommend that party (preferably under oath) complete a statement of information showing all of his US identifiers (DL, SSN, etc), spouse, children, a complete list of addresses he’s had in the US or elsewhere, and get a copy of his DL, birth certificate and passport.

Then use that additional information to compare with the (sometimes limited) information reported in the SDN hit.

In an abundance of caution, we suggest calling the OFAC hotline and try to get an email address to which you send all of the accumulated documents (encrypted and of course keeping a copy of that email). Then document your closing file with the date and time of the call.

Then, absent guidance from OFAC to the contrary, depending on whether there were any matches between the SDN Hit report and the statement of information, under Step 5, you may be able to take the position that it is not a valid match and close the transaction.

It is not uncommon for an SDN hit to have very little information about the restricted person, so even with a complete statement of information, this is not a totally comfortable answer.