Sanctions screening for small businesses and nonprofits: who needs it and how little is enough
US sanctions apply to every US person and company, not just banks. A small exporter, a freelance agency with foreign clients, a nonprofit making grants abroad or a marketplace seller shipping worldwide can all end up transacting with a listed person. Enforcement considers whether you had a reasonable process for your size. This guide describes a process that fits a one-person business.
Who should be screening
| Situation | Who to screen |
|---|---|
| Selling goods abroad (exporter, online seller, drop-shipper) | Buyers and ship-to parties outside the US, freight forwarders you did not choose. |
| Services for foreign clients (agency, consultant, developer) | The client company and the people who pay you. |
| Nonprofit with grants, partners or beneficiaries abroad | Grantees, local partners, vendors and individuals receiving funds. |
| Fintech, marketplace or payments start-up | Customers and merchants at onboarding, then periodically; your bank or processor will ask how. |
| Buying from foreign suppliers | The supplier and the account you pay, especially in high-risk regions. |
A proportionate process
- Decide which counterparties are in scope (usually everyone outside the US, and anyone you pay or receive from in a high-risk region).
- Screen each new counterparty against the SDN and Consolidated lists before the first transaction. Keep the record.
- Re-screen recurring counterparties periodically. Monthly is common; after every list update is better if the tool does it for you.
- Write down what you do in half a page: scope, tool, frequency, who reviews hits, where records live. That is your policy.
- When a hit looks real, stop and get advice. When it is a false positive, write one line why and keep going.
What this costs in time
A free single-name check takes about a minute including the record. A watchlist of up to a hundred names re-screened automatically costs nothing in time until a new hit appears; the monthly record email is the audit trail. Large one-off lists (a donor file, a customer export) are a batch job of a few minutes.
Limits of name screening
- Lists other than OFAC (EU, UK, UN, Commerce Entity List) are separate; check them if your trade touches those jurisdictions or export-controlled goods.
- Ownership: entities 50% or more owned by blocked persons are blocked without being listed. Screening cannot see that; for significant counterparties, ask for ownership information.
- Comprehensive embargoes (Cuba, Iran, North Korea, Syria, Crimea and other regions) prohibit most dealings with the territory regardless of names.
- Screening is not legal advice. Use it to decide when to ask for advice.
Free: one name against the SDN and Consolidated lists with a printable record. Watchlist: up to 100 names re-screened after every list update.
Free search PricingFAQ
Can OFAC fine a small business?
Yes. Civil penalties apply regardless of size, though OFAC's enforcement guidelines weigh the size and sophistication of the business and whether it had a compliance program. A documented, proportionate process is the best mitigation.
Is there a threshold below which I do not need to screen?
No dollar threshold exempts a transaction with a blocked person. Businesses choose their own risk-based scope; low-value domestic sales are usually out of scope, foreign payees are usually in.
Do payment processors screen for me?
Processors and banks screen their own customers and payments, and may block or ask about a transfer. That does not replace your check of the counterparty you chose, and a blocked wire is more disruptive than a one-minute check.
Can I use this for background checks on tenants or job applicants?
No. This service is for checking business counterparties, customers, payees and donors against sanctions lists. It is not a consumer report and must not be used for decisions about housing, hiring, credit or insurance.
Updated 2026-10-21. General information, not legal advice.