At a glance
- Who must comply
- Every U.S. person and business
- Screening method
- None set by law (OFAC FAQ 124)
- Report a blocked or rejected deal
- Within 10 business days
- Keep records
- 10 years
On this page
What an OFAC check is
An OFAC check compares a person's or company's name with the sanctions lists published by the Office of Foreign Assets Control, part of the U.S. Treasury: the Specially Designated Nationals (SDN) list and the consolidated lists. A dealer runs it on the buyer and any co-buyer before the deal closes. Run a free OFAC search.
Who must comply with OFAC regulations
All U.S. persons, which includes every U.S. business, must comply with OFAC's sanctions: they may not deal with a blocked person and must block that person's property. OFAC's general FAQs say so directly. There is no dealer exemption and no size threshold.
We found no OFAC page that mentions car dealers by name. Articles that say "OFAC checks are required for dealers" overstate it, as the next section explains.
Are OFAC screening requirements written in law?
OFAC requires no specific screening method; screening is how dealers avoid prohibited deals.
OFAC's FAQ 124 says its regulations "do not explicitly require any specific screening regime." The legal duty is the ban on dealing with blocked persons, and violations can be penalized even without intent. OFAC's enforcement guidelines (31 CFR Part 501, Appendix A) treat a risk-based compliance program as a mitigating factor. In practice, screening every buyer is how a dealer shows it took the ban seriously.
What transactions are covered
OFAC's reporting rule defines a transaction to include "sales or purchases of goods or services" (31 CFR 501.604). For a dealership that means:
- Selling or leasing a car to a buyer.
- Arranging financing for the buyer.
- Buying a car or a trade-in from someone.
- Selling to a company: check the company name.
A simple OFAC program for a dealership
Check every buyer and co-buyer
Before the contract is signed, search each name. Use the full legal name from the license.
Clear possible matches with details
Compare date of birth, address and nationality with the list entry. Write down why it isn't a match, who checked and when.
Stop on a likely true match
Don't complete the deal. Contact OFAC. Report a rejected or blocked transaction within 10 business days.
Keep the result
Put the dated result in the deal jacket and keep records at least 10 years.
Train the desk
Salespeople and the F&I office should know when to run the check and what a possible match means.
OFAC deadlines
| What | When | Rule |
|---|---|---|
| Rejected transaction report | Within 10 business days | 31 CFR 501.604 |
| Blocked property report | Within 10 business days | 31 CFR 501.603 |
| Yearly blocked property report | By September 30 | 31 CFR 501.603 |
| Records | At least 10 years | 31 CFR 501.601 |
Rules checked and limits
Rules checked October 31, 2026. We read every rule on this page in the eCFR or on the agency's own site, and each is linked in the sources below. We re-check them every quarter.
Templates and tools, not legal advice. CarShots is software, not a law firm. For a question about your own dealership, ask your attorney or your state dealer association.