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.
Why It's Not Optional
OFAC updates the SDN List on no fixed schedule, often more than once a week (OFAC FAQ 20), often with immediate effect.
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.
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
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.
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.govARCO 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-programsA 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 DESIGNATIONWhat You'll See
No match against the SDN list or the country sanctions programs. That covers both parties, their owners, the origin countries and the transit countries.
A fuzzy name match below the confidence threshold, flagged for a compliance officer's review, with a full override audit trail.
Confirmed match on the SDN list or an active comprehensive country embargo applies.
Coverage Detail
| Check | What's verified | Refresh cycle |
|---|---|---|
| OFAC SDN list | Buyer, seller, and beneficial owner name matching | On new designation |
| Country sanctions programs | Origin and transit country embargo status | On OFAC program change |
| Pre-screen expiry | Re-screening enforced by the platform per swap | 72 h / 24 h (MENA/China tightened) |
| Compliance officer override | Manual review workflow with full audit trail | On PENDING result |
Related Compliance
Request a walkthrough and see sanctions screening run in the demo.