OFAC Download and Name Match Documentation

Back Office Section Heading OFAC Download and Name Match Documentation

This document provides technical guidance for users of the FLEX system regarding the OFAC Download and Name Match functionality.

1. Introduction to OFAC

The Office of Foreign Assets Control (OFAC) is a department within the U.S. Department of the Treasury. It is responsible for administering and enforcing economic and trade sanctions. These sanctions are implemented based on U.S. foreign policy and national security objectives, targeting:

  • Foreign countries and regimes
  • Terrorists
  • International narcotics traffickers
  • Entities involved in the proliferation of weapons of mass destruction
  • Other threats to the national security, foreign policy, or economy of the United States.

2. OFAC SDN/CONSOLIDATED Name Match Overview

The OFAC Name Match program in the FLEX system allows users to compare credit union member names against government-issued lists, specifically the Specially Designated Nationals (SDN) and Consolidated (CONSOLIDATED) lists.

Key Functionality:

  • Compares selected names within the FLEX system to the downloaded OFAC files.
  • Generates a report listing possible matches.
  • The duration of the program run is directly proportional to the number of matches requested.

3. Pre-Requisites: Downloading OFAC Data Files

Before running the OFAC Name Match program, you must download the latest SDN master list and PLC master list from the U.S. Treasury website.

3.1. Preparing the FLEX Drive OFAC Folder

  1. Verify and Delete Existing Files:
    • Navigate to the OFAC folder within your FLEX drive.
    • Ensure no files or folders are present.
    • If any exist, delete them before proceeding.
  2. Remove Previous Download Files from C:drive:
    • Search for SDN.XML and CONSOLIDATED.XML files on your C:drive.
    • Delete any instances of these files.

3.2. Downloading the SDN File

  1. Access Treasury Website:
    • Go to: http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx
  2. Locate SDN List:
    • Find the “Specifically Designated Nationals List (SDN.XML List)”.
  3. Save File:
    • In the “Save As” window, click “Browse” or “Save In”.
    • Select the Desktop folder as the save location.
    • Click “Save”.
  4. Completion:
    • The SDN.XML data file will download to your Desktop.
    • Click “Close” once the download is complete.

3.3. Downloading the Consolidated File

  1. Access Treasury Website:
    • Go to: http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/consolidated.aspx
  2. Locate and Save:
    • Find CONSOLIDATED.XML.
    • Right-click on the file and select “Save Link As”, “Save As”, or “Save Target As”.
  3. Save File:
    • In the “Save As” window, click “Browse” or “Save In”.
    • Select the Desktop folder as the save location.
    • Click “Save”.
  4. Completion:
    • The CONSOLIDATED.XML data file will download to your Desktop.

4. Moving Downloaded Data Files to FLEX Drive

After downloading, the SDN.XML and CONSOLIDATED.XML files must be moved to the OFAC folder on your FLEX:drive.

4.1. Moving SDN.XML

  1. Locate File:
    • Go to your Desktop folder and find the SDN.XML file.
    • Right-click on the file and select “Copy”.
  2. Paste to FLEX Drive:
    • Navigate to the OFAC folder in your FLEX:drive.
    • Right-click within the folder and select “Paste”.
  3. Verification:
    • The SDN.XML file should now appear in the OFAC folder.

4.2. Moving CONSOLIDATED.XML

  1. Locate File:
    • Go to your Desktop folder and find the CONSOLIDATED.XML file.
    • Right-click on the file and select “Copy”.
  2. Paste to FLEX Drive:
    • Navigate to the OFAC folder in your FLEX:drive.
    • Right-click within the folder and select “Paste”.
  3. Verification:
    • The CONSOLIDATED.XML file should now appear in the OFAC folder in the FLEX:drive.

Note: The U.S. Treasury Department may modify its website, which could lead to changes in the download process. If you encounter difficulties locating the correct files due to website changes, contact FLEX Support for assistance.

5. Running OFAC Name Match in FLEX

Once the OFAC files are correctly downloaded and moved to the FLEX:drive, you can run the OFAC Name Match program.

5.1. Accessing the Program

  1. From the FLEX Main Menu, navigate to Internal Audit.
  2. Select OFAC.
  3. Choose OFAC Name Match.

5.2. OFAC Name Match Program Options

The OFAC Name Match program presents several configuration options to tailor the matching process.

5.2.1. General Instructions

  • Pre-requisite Reminder: Reiterate the necessity of downloading the latest Windows delimited SDN master list and PLC master list from the US Treasury website.
  • Instructions Location: Complete instructions for obtaining these files and their required location on the iSeries are available from www.cmcflex.com downloads page. Contact the support department for assistance if website access is not possible.
  • Program Function: The program compares downloaded files to selected names and generates a report of possible matches. The more matches requested, the longer the program will run.

5.2.2. File Options

  • Downloaded And Copied US Treasury Files:
    • Indicates which previously downloaded file from the US Treasury website will be used for the match.
  • Ignore Account Bypass File:
    • Yes: The program will run without using the bypass file.
    • No: The program will run with the bypass file.
  • Sort Option:
    • Determines how the results in the generated report will be sorted.

5.2.3. Match Other Files

These options allow you to specify additional credit union data files to match against. Select “Yes” or “No” for each:

  • Match Names With Joint Owners
  • Match Names With Co-Borrowers
  • Match Names With Beneficiaries
  • Match Names With Check File
  • Match Accounts Payable Vendors
  • Match With Authorized Signers

5.2.4. Name Match Options

These options define the criteria for name matching:

  • Match First, Middle, And Last Name:
    • Indicates whether to match against the full name (First, Middle, Last).
  • Match OFAC Business Names With Last Name:
    • Indicates whether to match OFAC business names against last names.
  • Match OFAC Business Names With Business Name:
    • Indicates whether to match OFAC business names against other business names.
  • First Name Contiguous Characters For Match:
    • Specify the minimum number of contiguous characters that must match for the first name.
  • Middle Name Contiguous Characters For Match:
    • Specify the minimum number of contiguous characters that must match for the middle name.
  • Last Name Contiguous Characters For Match:
    • Specify the minimum number of contiguous characters that must match for the last name.

6. Post-Match Procedures

After running the OFAC Name Match program, a report will be generated.

6.1. Handling SDN List Matches

If the report indicates a match to the Specially Designated Nationals (SDN) list (either through manual checking or software use), proceed as follows:

  1. Internal Policies and Procedures: Follow your credit union’s internal policies and procedures for handling OFAC matches.
  2. OFAC Hotline: For additional questions or concerns regarding a possible match, contact the Office of Foreign Assets Control’s (OFAC) Hotline at 1-800-540-6322.