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Got a possible match? What a false positive looks like and what to do

The SDN list contains thousands of individuals with common Spanish, Arabic, Russian and Chinese names, plus aliases and spelling variants. Any fuzzy search will return hits for names like Juan Garcia or Mohammad Ali. A hit is a prompt to look, not a finding. This guide shows what a false positive usually looks like and how to clear one properly.

Signs of a false positive

  • The programs make no sense for your counterparty: a narcotics-trafficking tag for a software vendor in Germany.
  • Different country: the listing's addresses and nationality are elsewhere and your counterparty has no link there.
  • Date of birth is off by years, or the listing has a date of birth and your counterparty's does not fit.
  • Different entity type: the listed name is a vessel or aircraft and you are dealing with a company, or vice versa.
  • The match is on a weak alias (initials, an abbreviation) rather than the primary name.
  • The score is in the 'possible' range only because of a shared common word.

Signs it may be real

  • Exact match on the primary name or a strong alias, and the country matches.
  • For individuals, the date of birth or an identifier (passport, national ID) matches.
  • The programs fit the counterparty's sector or location (for example a Russian defense supplier with an EO 14024 tag).
  • The counterparty is evasive about ownership or asks you to route payment through a third party.

How to clear a false positive

  1. Open the official OFAC entry for the hit and read the full record: aliases, addresses, nationality, dates of birth, identifiers, remarks.
  2. Write down, in one or two lines, which facts show it is not your counterparty (different country of residence and date of birth, different sector, and so on).
  3. Attach that note to the screening record and the transaction file.
  4. If any identity detail matches or you cannot verify the counterparty's details, do not proceed; contact OFAC's online Compliance Hotline (ofac.treasury.gov/ofac-compliance-hotline) or ask a sanctions professional.

What not to do

  • Do not ignore the hit because the name is common. The record should show you looked.
  • Do not accuse the counterparty of being sanctioned. Ask for ordinary identity documents if you need them to compare.
  • Do not rely on a single search engine result or a screenshot without the list version and time.
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FAQ

How often are hits false positives?

For small businesses screening ordinary customers and suppliers, nearly all of them. Real hits are rare but costly, which is why documenting the review matters.

Should I block a payment while I review?

If the hit is credible, do not complete the transaction until it is resolved. For an obvious false positive (different country, different person), document and proceed. When unsure, ask the hotline; it exists for this.

Can I ask the counterparty for their date of birth or passport?

Yes, as part of normal know-your-customer checks. Use it only to compare with the listing and keep only what you need.

Updated 2026-10-22. General information, not legal advice.

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