Question 1

What does it mean to "clear" a screening alert?

Accepted Answer

Clearing a screening alert means reviewing a potential match and determining that the screened party is not the same person as the sanctioned individual. This is a formal compliance decision — not a one-click dismissal. A proper clear requires comparing identifying data, recording your rationale, and documenting the decision in the screening record. OFAC expects schools to be able to show why they cleared an alert, not just that they did.

Question 2

When should an alert be escalated instead of cleared?

Accepted Answer

Escalate when: (1) the name match is exact or very close and identifying information is thin or missing, (2) the nationality or country of origin matches the sanctioned party, (3) the date of birth is the same or very close, (4) the match involves a high-risk sanctions program (e.g., Iran, North Korea, cartels), or (5) the reviewer is uncertain. Escalation should go to a senior compliance officer or legal counsel — not back to the admissions or business office.

Question 3

What information should I record when clearing an alert?

Accepted Answer

For each cleared alert, record: the name screened, the matched SDN entry, the source list, what identifying data you compared (e.g., "DOB does not match: screened party born 1998, SDN entry born 1961"), the specific reason for clearing, and your name and the date of review. SecurePoint Education captures this automatically in the case review form.

Question 4

What happens if a school clears an alert incorrectly and the party is actually sanctioned?

Accepted Answer

If a school accepts tuition or donations from a party who is on the SDN list, OFAC can assess civil penalties regardless of intent. However, a documented review showing the school made a good-faith effort to compare identifying data — and recorded its reasoning — substantially reduces penalty exposure compared to no review at all. OFAC considers the quality of the compliance program as a mitigating factor in penalty calculations.

Question 5

How long do we need to keep adjudication records?

Accepted Answer

OFAC guidance recommends retaining compliance records for at least five years. This includes the original screening result, the reviewer's decision and rationale, and any evidence packs generated. SecurePoint Education stores these records automatically and makes them exportable on demand.

Question 6

Is a high confidence score the same as a true positive?

Accepted Answer

No. Confidence scoring reflects how closely the screened name matches an entry on the sanctions list — it is a starting point for human review, not a final determination. A 95% confidence score means the names are very similar; it does not confirm the two people are the same individual. Matching date of birth, nationality, and other identifiers is required to make that determination.

Question 7

What is a "common name" false positive and how should it be handled?

Accepted Answer

Common-name false positives occur when a screened party shares a name with an SDN-listed individual but is clearly a different person. For example, a domestic U.S. student named "Mohamed Al-Hassan" may match an SDN entry of the same name with a completely different date of birth and nationality. Document the comparison explicitly — note the specific data points that differ — and clear with a rationale. This provides a defensible record if the decision is ever reviewed.

A screening alert is not a violation — it is a review requirement

Four steps for reviewing and clearing a screening match

Assess the match: confidence level and source list

Compare identifying data: DOB, nationality, address, and context

Record your rationale: document what you compared and what you found

Decide: clear, escalate, or block

Six data points that determine whether to clear or escalate

Confidence score

Date of birth

Nationality and country context

Name spelling variants and aliases

Sanctions program details

Reviewer notes and prior decisions

All match data, side by side — with a structured rationale field

Clearing OFAC screening alerts — FAQ for schools

Education compliance resources

OFAC Compliance Checklist for Schools

Compliance Evidence Packs

OFAC Licensing Paths

Continuous Monitoring

Education White Paper

Plans & Pricing

Review every match with a structured, documented workflow