One-Time vs Ongoing OFAC Screening for Names and Wallets

Short answer: A one-time OFAC check tells you whether a name or wallet address matched the sanctions lists on the day you looked. It does not tell you about tomorrow. OFAC adds and changes entries regularly, so a customer, vendor or wallet that was clear when you onboarded it can be listed later. Ongoing screening re-checks the entries you care about after list updates and alerts you to a possible match.

OFAC Watcher is one way to run that daily watch, covered below.

What the OFAC lists are

The US Treasury's Office of Foreign Assets Control publishes the Specially Designated Nationals and Blocked Persons List (SDN) and other sanctions lists. US persons are generally prohibited from dealing with listed parties, subject to specific rules and licenses. Some SDN entries include digital currency addresses. The United Nations and the European Union keep their own lists, which overlap with OFAC's but are not identical.

OFAC offers a free official Sanctions List Search tool. It is the authoritative place to look a name up.

The gap a one-time check leaves

Think of three moments:

1. Day 1. You check a new vendor. No match.
2. Month 4. OFAC designates that vendor or a related party.
3. Month 6. You pay another invoice.

Nothing in your process told you about Month 4. A one-time check was correct when you ran it. The problem is time.

This matters more for parties you deal with repeatedly: recurring vendors, customers with ongoing accounts, counterparties in crypto who send or receive funds more than once, and wallets you whitelist.

One-time screening: when it fits

• A single transaction with a party you will not deal with again.
• A quick pre-check before deeper diligence.
• Documenting that you looked on a specific date.

Free tools, including OFAC's own search, cover this well.

Ongoing screening: when it fits

• You have a list of customers, vendors or wallet addresses you deal with again and again.
• You want to know soon after a list update if one of them may match.
• You want a record of when entries were checked.

How to set up a simple ongoing process

1. Make the watch list. Every recurring counterparty name and every wallet address you whitelist or pay repeatedly.
2. Choose your lists. At minimum OFAC SDN. Add UN and EU if you deal internationally.
3. Decide the cadence. Daily is common because lists can change on any business day.
4. Define what happens on an alert. Who reviews it, how a possible match is confirmed or cleared, and when to pause activity and get advice.
5. Keep a record. Note when each alert was reviewed and the outcome.

A possible match is not a confirmed match. Common names and partial matches create false positives. Review each one carefully, and talk to a qualified professional before acting on a real one.

Crypto wallets: a specific case

Because some SDN entries list specific digital currency addresses, an exact wallet address can be compared against the list. That is more precise than name matching, but it only catches addresses that are on the list. It does not detect indirect exposure through other wallets. For deeper on-chain review of a single wallet, a separate risk report such as TRACR looks at public on-chain data.

Where OFAC Watcher fits

OFAC Watcher is a low-cost daily watch. You add wallet addresses and entity names, it checks them against the OFAC SDN, UN and EU lists each day, and it emails you when a watched entry may match. It is a monitoring aid, not a compliance program, and it does not decide whether a match is real or what you must do about it.

Start watching with OFAC Watcher

Questions your written screening process should answer

Whether you use software or a spreadsheet, write down the answers to these questions so the process survives staff changes:

• Who is screened? New customers, vendors, payees, and which counterparties are added to the ongoing watch list.
• When? At onboarding, before payment, and on what recurring cadence after that.
• Against what? Which lists, and whether you include UN, EU or other lists in addition to OFAC.
• How are possible matches handled? Who reviews, what extra information they compare (dates of birth, addresses, identifiers), and how a decision is recorded.
• When is activity paused? The trigger for holding a payment or transaction while a possible match is reviewed.
• When is outside advice sought? A clear rule for escalating to counsel or a compliance professional.
• How long are records kept? Where screening results and review notes are stored and for how long.

Signs your current approach has a gap

• You screen at onboarding but have never re-screened existing counterparties.
• Your watch list lives in one person's spreadsheet.
• Wallet addresses you pay or accept funds from are not checked at all, only names.
• Nobody can say when the last list update was compared against your customers.
• Possible matches are cleared without a written note of why.

If any of these sound familiar, the simplest first step is to build the watch list and start a daily check. That covers the time gap a one-time check leaves, and it gives you a dated record that the check was done.

Firm deadline tracking is a separate job from sanctions screening. Bar dues, CLE and insurance renewals belong on a list such as SinceFiled. See the recurring compliance deadlines small law firms miss.

Cost of the options

• Free: OFAC's own Sanctions List Search, for manual one-off lookups.
• OFAC Watcher: USD 29 a month for a daily watch of wallets and entities with email alerts, at OFAC Watcher.

Related reading

• The recurring compliance deadlines small law firms miss
• Is my law firm cited by ChatGPT?
• How AI engines choose which lawyers to recommend

Related tools

• OFAC Watcher. Daily checks of wallet addresses and entity names against the OFAC SDN, UN and EU lists for USD 29 a month.
• SinceFiled. The Firm plan is USD 49 a month, or Lifetime is USD 329 one time.
• FirmCited audit. The FirmCited audit is USD 490 one time: 25 prompts, up to 4 engines, a 10-page fix list, under 48 hours.
• FirmCited Monitor. FirmCited Monitor is USD 299 per month, cancel anytime.

FAQ

What is the difference between one-time and ongoing OFAC screening?

One-time screening checks a party on a single date. Ongoing screening re-checks saved parties after list updates and alerts you to possible new matches.

How often does the OFAC list change?

OFAC updates its lists as designations and removals happen, which can be on any business day. Check OFAC's recent actions page for the record.

Can I check a crypto wallet against OFAC?

Yes, for addresses OFAC has published in SDN entries. An exact address comparison only finds addresses on the list.

Is the OFAC search tool free?

Yes. OFAC's Sanctions List Search is free and is the official source.

Does a possible match mean I am in violation?

No. A possible match needs review. Many are false positives. Get qualified advice before acting on a confirmed match.

Which lists does OFAC Watcher check?

The OFAC SDN list, the UN list and the EU list, each day.

How much does OFAC Watcher cost?

USD 29 a month.

Disclaimer

General information and software only - not legal advice, no attorney-client relationship. Consult a licensed attorney.

Reports are generated with AI-assisted software and may contain errors. Review before relying on them.