● SANCTIONS SCREENING — CONTINUOUS

Sanctions screened on both sides, every time — automatically.

A single new OFAC designation can turn a cleared swap into a criminal liability overnight. Michael's ARCO module screens both counterparties, their beneficial owners and the origin and transit countries against the published SDN list before a swap proceeds. Every cleared result expires. A stale screen can never carry a swap forward.

See the pipeline

Why It's Not Optional

The stakes of getting sanctions screening wrong

Update frequency
No fixed schedule

OFAC updates the SDN List on no fixed schedule, often more than once a week (OFAC FAQ 20), often with immediate effect.

Pre-screen window
72 h / 24 h

ARCO pre-screens expire after 72 hours on EU/US corridors. On any corridor that touches MENA or China they expire after 24 hours. So nobody can use a stale result after a new designation lands.

Screening scope
4 dimensions

Four dimensions: the buyer entity, the seller entity, the beneficial owners on both sides, the commodity's origin and transit countries.

A pre-screen, not a ruling. ARCO screens swaps against published regulatory and sanctions lists and gates the workflow on the result. It is not a legal determination, a regulatory filing, or a substitute for your compliance function's formal sign-off.

How ARCO Handles It

The sanctions screening pipeline, automated

ARCO screens every swap against the published OFAC SDN list and the Country Sanctions Programs before it issues a pre-screen result. It screens again on any new designation during the validity window.

01

Entity & beneficial owner screening

ARCO matches the buyer entity, the seller entity and their beneficial owners against the SDN list. ARCO calibrates the fuzzy matching to control false positives.

SOURCE: sanctionslist.ofac.treas.gov
02

Origin & transit country check

ARCO checks the commodity's origin and transit countries against the OFAC Country Sanctions Programs list. The list covers comprehensive embargoes and partial restrictions.

SOURCE: ofac.treasury.gov/sanctions-programs
03

Pre-screen with expiry

A cleared pre-screen is valid for 72 hours (24 hours on MENA/China corridors). If a new designation lands within that window, the platform forces re-screening before the swap can proceed.

RE-SCREEN: FORCED ON NEW DESIGNATION

What You'll See

Three possible outcomes, every time

CLEARED

No match against the SDN list or the country sanctions programs. That covers both parties, their owners, the origin countries and the transit countries.

PENDING

A fuzzy name match below the confidence threshold, flagged for a compliance officer's review, with a full override audit trail.

BLOCKED

Confirmed match on the SDN list or an active comprehensive country embargo applies.

Coverage Detail

What ARCO checks, and how current it is

CheckWhat's verifiedRefresh cycle
OFAC SDN listBuyer, seller, and beneficial owner name matchingOn new designation
Country sanctions programsOrigin and transit country embargo statusOn OFAC program change
Pre-screen expiryRe-screening enforced by the platform per swap72 h / 24 h (MENA/China tightened)
Compliance officer overrideManual review workflow with full audit trailOn PENDING result

Related Compliance

OFAC is one of several gates every swap runs through

Screen a swap before you commit to a deal.

Request a walkthrough and see sanctions screening run in the demo.