OFAC/Sanctions Screening & Partner-Vetting Checklist
The compliance gate that must clear before any funds, goods, or grants move to an overseas partner, vendor, or beneficiary group — operationalizing US sanctions and counter-terrorism-financing law into a repeatable process.
Draft: pending review
This starter document is signed off by International-NGO counsel (OFAC/sanctions + AML/CFT) + compliance officer before it ships. The guardrails below define that review.
What’s inside
- Screening steps: run partners, personnel, and vendors against OFAC SDN and consolidated lists (with re-screening cadence)
- Country/region risk tier: comprehensively sanctioned, embargoed, or requiring a specific OFAC license?
- Documentation: screening date, list versions, results, approver sign-off, retention period
- Red-flag escalation and 'do not proceed / seek counsel or license' decision tree
Legal & ethical guardrails
The sector-specific compliance points this document must honor.
- OFAC strict liability applies regardless of charitable intent — and a party need not be SDN-listed to be blocked if it is ≥50% owned by SDN(s) (the OFAC 50% Rule); screen beneficial ownership, not just the lists. Check whether a self-executing humanitarian GENERAL LICENSE already authorizes the activity before assuming a specific license is required
- Counter-terrorism financing: US law prohibits material support to designated organizations; partner and downstream-beneficiary diligence is mandatory
- FCPA linkage: vetting should flag foreign-official relationships and bribery risk in the partner chain
- Data protection: screening processes personal data; store and share results lawfully and securely
Held for professional review.
The native PDF and full working text ship only after sign-off by International-NGO counsel (OFAC/sanctions + AML/CFT) + compliance officer on this exact version. The summary and review requirements remain visible in the meantime.
Not legal advice. Not legal, tax, or accounting advice. The Fundraising Co. provides educational fundraising materials and is not a law firm; nothing here creates an attorney–client relationship or substitutes for advice from professionals licensed in your jurisdiction. Laws and IRS rules vary by state and change over time. Review every document with qualified counsel before use.