OFAC, A Framework for OFAC Compliance Commitments: a risk-based sanctions compliance program (OFAC, A Framework for OFAC Compliance Commitments (May 2019))
OFAC does not set a fixed screening step in the regulations I read. It strongly encourages a risk-based program, so a US buyer screening each new holder against the SDN list is its expected practice, not a written duty.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“OFAC strongly encourages organizations subject to U.S. jurisdiction, as well as foreign entities that conduct business in or with the United States, U.S. persons, or using U.S.-origin goods or services, to employ a risk-based approach to sanctions compliance by developing, implementing, and routinely updating a sanctions compliance program (SCP).”
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide