OFAC Introduces New SDN Data Production System

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) on June 13, 2012 released the following:

“OFAC has just launched a new, internal Specially Designated Nationals (SDN) and Blocked Persons List production system. This system is designed to emulate existing SDN data formats so that OFAC’s internal transition should be relatively transparent to the public. However, certain long-standing (but minor) problems with OFAC’s current data formats were corrected and users of the emulated SDN data will see some changes to records that are administrative only.

The following administrative changes have been made to SDN data in the emulated formats.

  1. All SDN data in the human-readable files now end in a period (.) . The period will serve as a true end of line marker from this point forward.
  2. Data that were produced with no specific ordering rules in the past now have ordering rules applied. For example, weak aliases in the remarks fields of the fixed-width and delimited files could change position within the remarks field from publication to publication. This will no longer occur. Specific ordering has also been applied to other data in the remarks (identification information like passport number, cedula number, etc. will appear in a consistent order from publication to publication).
  3. Extra/erroneous spaces that appeared in SDN records have been removed.
  4. Dates in the SDN data files could be published in variable formats. The following formats were allowed: D MMM YYYY; DD MMM YYYY; D MMM YY; DD MMM YY. Now all dates will be published in a single format DD MMM YYYY. Single digit days will now be padded with a 0 in front of the actual day.
  5. In the past OFAC used the abbreviation “c/o” in the address field of its data and human-readable files to describe a relationship between two or more SDNs. In the newly produced data files relationships between SDNs will be more clearly defined using the phrase, “Linked To:” as the following example shows.
  6. TEST COMPANY (a.k.a. BIG TEST COMPANY), Test Street 1, Test Street 2, Test Street 3, Test City, Test State Test Province, Test Country; Remarks Field test [IRAQ] Linked To: TEST, Joe.

    The “Linked To:” descriptor will start appearing in newly created SDNs. OFAC may replace older “c/o” records with “Linked To:” over time.

  7. Certain e-mail addresses in the OFAC data were associated with a specific country. That association has been removed.
  8. There was an inconsistency in the program codes presented in the human-readable SDN files as compared to the machine-readable files with regard to Zimbabwe. In the machine-readable SDN files the program code for Zimbabwe was ZIMB. In the human-readable files it was ZIMBABWE. The code is now ZIMBABWE in both sets of files.
  9. Dates of birth may now feature date ranges in place of “circa” values for new designations.
  10. Records in ADD.* files are now always ordered by ent_num and then by add_num. Records in ALT.* files are now always ordered by ent_num and then by alt_num.
  11. The SDN.XML file is now ordered by UID.

For the next few days the SDN data files that are produced by OFAC’s old SDN production system will be available in their current location. The new files will be available for download and testing. We STRONGLY encourage users of these data to download and review of the emulated SDN files. These files can be found here.

If you have any difficulty loading these new files into your screening systems, please contact OFAC immediately by e-mail at O_F_A_C@do.treas.gov. Please be as detailed as possible when describing your problem.”

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Douglas McNabb – McNabb Associates, P.C.’s
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Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

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