# OFAC Sanctions Screening: Who You Cannot Ship To

Source: https://landedgehq.com/blog/2026-11-14-ofac-sanctions-screening/

Cross-border operations guide · November 14, 2026


**Short answer:** OFAC, the Treasury Department's Office of Foreign Assets Control, administers U.S. sanctions, and its Specially Designated Nationals list names the people and entities Americans cannot do business with. Screening means checking every party to a transaction, the customer, the end user, the freight forwarder, the bank, and the destination, against the SDN list and the other restricted-party lists, before the shipment moves. The penalty for skipping it is not a fine. It is a violation with civil penalties that can reach the value of the transaction and criminal penalties for willful violations.

## The list is the law, and it changes daily

OFAC screening starts with a fact that surprises first-time exporters: the sanction is on the person, not the country. The Specially Designated Nationals and Blocked Persons list names individuals, companies, vessels, and aircraft, and any transaction with a listed party is prohibited, wherever in the world it takes place and whatever the product is. The list is updated constantly, sometimes daily, which means a screening that was clean last month may not be clean today, and a shipment that was lawful when it was booked may not be lawful when it sails.

The Bureau of Industry and Security runs the parallel system for export controls, and the two lists overlap but do not match. BIS maintains the Entity List, the Denied Persons List, and the Unverified List, and a party can sit on one list without sitting on the other. The Reidel guide to BIS compliance makes the operational point: screening means checking every list, not the one the exporter remembers, because the lists answer different questions, and a clean result on one is not a clean result on the other.

## Who to screen, and when

Screen every party to the transaction, not just the customer. The end user, the freight forwarder, the bank that processes the payment, the consignee, and any intermediary who touches the goods. A shipment to a clean customer through a listed forwarder is a violation. A payment routed through a listed bank is a violation. The screening has to follow the money and the goods, not just the purchase order, because OFAC's jurisdiction follows the transaction, and the transaction includes everyone who participates in it.

Screen before the shipment moves, and screen again when the terms change. A change in destination, a change in end user, a change in the routing, or a delay that pushes the shipment past a list update all justify a fresh screen. The screening should be documented, with the date, the lists checked, and the result, because the documentation is the defense. An exporter who screened, found nothing, and kept the record has a story to tell. An exporter who never screened has nothing to say, and the penalty is the same either way.

## The penalty, and the one control that prevents it

The penalties are the reason screening is not optional. Civil penalties for sanctions violations can reach the value of the transaction, and willful violations carry criminal penalties, including fines and imprisonment for the individuals involved. The amounts are large because the conduct is treated as a national security matter, not a paperwork error, and the enforcement does not require the exporter to have intended the violation. Strict liability means the violation is the violation, and the exporter's intent is relevant only to how large the penalty is.

The one control that prevents it is a screening step built into the order process, not a manual check someone remembers to run. When an order is entered, the system screens the parties against the current lists, and the order does not proceed until the screen clears. The screening is automated, the lists are updated automatically, and the result is logged with the order. An exporter who relies on memory will miss a list update. An exporter who relies on a system will not, and the system costs less than a single penalty. For the export control side of the same shipment, [ECCN versus EAR99](https://landedgehq.com/blog/2026-11-13-eccn-vs-ear99-license-check/) covers the license check, and [denied party screening for exports](https://landedgehq.com/blog/2026-11-13-denied-party-screening-export/) goes deeper on the lists themselves.

Screening is not a one-time check at onboarding. Lists change, and a customer who was clear last year may not be clear today, so the screening has to run on every order, not just the first one.

## Frequently asked questions

### What is OFAC, and what does it do?

The Treasury Department's Office of Foreign Assets Control administers U.S. sanctions. Its Specially Designated Nationals list names the people and entities Americans cannot do business with, and any transaction with a listed party is prohibited, wherever it takes place.

### Who do I need to screen before shipping?

Every party to the transaction: the customer, the end user, the freight forwarder, the bank, the consignee, and any intermediary. A shipment to a clean customer through a listed forwarder is a violation, because OFAC's jurisdiction follows the transaction.

### How often do the sanctions lists change?

Constantly, sometimes daily. A screening that was clean last month may not be clean today, so screen before the shipment moves and again when the terms change, and document the date, the lists checked, and the result.

### What is the penalty for an OFAC violation?

Civil penalties can reach the value of the transaction, and willful violations carry criminal penalties including fines and imprisonment. The conduct is treated as a national security matter, and enforcement does not require the exporter to have intended the violation.