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308 lines
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308 lines
14 KiB
Plaintext
OFFICE OF FOREIGN ASSETS CONTROL
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U.S. TREASURY DEPARTMENT
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SPECIALLY DESIGNATED NATIONALS AND BLOCKED PERSONS
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DATA SPECIFICATION
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First Released: 12/06/2004
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Updated: 09/25/2023
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PLEASE NOTE IMPORTANT INFORMATION REGARDING THE TECHNICAL STRUCTURE
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OF THESE FILES ARE FEATURED AT THE BOTTOM OF THE DOCUMENT
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OFAC is now publishing its list of Specially Designated Nationals in XML
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and Comma delimited (CSV) format. These digital publications as
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transmitted by OFAC are designed as reference tools providing actual notice of
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actions by OFAC with respect to Specially Designated Nationals and other
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entities whose property is blocked, to assist the public in complying with the
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various sanctions programs administered by OFAC. The latest changes may appear
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here prior to their publication in the Federal Register, and it is intended that
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users rely on changes indicated in these documents that post-date the most
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recent Federal Register publication with respect to a particular sanctions
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program in the appendices to chapter V of Title 31, Code of Federal Regulations.
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Such changes reflect official actions of OFAC, and will be reflected as soon as
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practicable in the Federal Register under the index heading "Foreign Assets
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Control." New Federal Register notices with regard to Specially Designated
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Nationals or blocked entities may be published at any time. Users are advised
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to check the Federal Register and these electronic publications routinely for
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additional names or other changes to the listings. Entities and individuals on
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the list are occasionally licensed by OFAC to transact business with U.S.
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persons in anticipation of removal from the list or because of foreign policy
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considerations in unique circumstances. Licensing in anticipation of official
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Federal Register publication of a notice of removal based on the unblocking of
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an entity's or individual's property is reflected in these publications by
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removal from the list. Current information on licenses issued with regard to
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Specially Designated Nationals and other blocked persons may be obtained or
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verified by calling OFAC Licensing at (202) 622-2480.
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Technical Specification:
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Format *.ff consists of records separated by carriage returns, with fields
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within the records beginning at fixed locations.
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Format *.csv consistes of records seperated by carriage returns (ASCII character
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13), with fields (values) within records delimited by the "," (comma) symbol
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(ASCII character 44).
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Null values for all four formats consist of "-0-" (ASCII characters 45, 48, 45).
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The Comma Seperated Values (.csv), and Fixed-Field (.ff) releases consist of three ASCII text files--a main
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file listing the name of the SDN and other information unique to that entity
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(sdn.*), a file of addresses (add.*), and a file of alternate names (alt.*).
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Addresses and alternate names are linked to particular SDNs using unique integer
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values in a linking or primary key column. The integers used are assigned for
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linking purposes only and do not represent an official reference to that entity.
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Releases of the database-format files are intended as a service to the user
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community. OFAC's SDN list is published in the Federal Register. All of OFAC's
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lists are drawn from the same underlying data and every effort has been made to
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ensure consistency. The Federal Register will govern should differences arise.
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Due to the nature, urgency, and sensitivity of the programs which OFAC
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administers and enforces, it may not always be possible to provide advanced
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notice to users of format changes to the database structure.
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The files associated with each release are:
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fixed field: SDN.FF, ADD.FF, ALT.FF, SDN_COMMENTS.FF
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Comma delimited: SDN.CSV, ADD.CSV, ALT.CSV, SDN COMMENTS.CSV
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XML: SDN.XML, SDN_ADVANCED.XML
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Misc: dat_spec.txt (this file), sdn.xsd (XML SDN schema),
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sdn_advanced.xsd (advanced XML SDN schema).
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FORMAT SDN FIXED FIELD
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Main table, text file name SDN.FF
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Column Posi-
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sequence Column name Type Size tion Description
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-------- ----------- ------- ---- ---- ---------------------
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1 ent_num number 10 10 unique record
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identifier/unique
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listing identifier
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2 SDN_Name text 350 11 name of sdn
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3 SDN_Type text 12 361 type of SDN
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4 Program text 200 373 sanctions program name
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5 Title text 200 573 title of an individual
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6 Call_Sign text 8 773 vessel call sign
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7 Vess_type text 25 781 vessel type
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8 Tonnage text 14 806 vessel tonnage
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9 GRT text 8 820 gross registered
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tonnage
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10 Vess_flag text 40 828 vessel flag
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11 Vess_owner text 150 868 vessel owner
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12 Remarks text 1000 1018 remarks on SDN*
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END OF ROW 2018
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Address table, text file name ADD.FF
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Column Posi-
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sequence Column name Type Size tion Description
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-------- ----------- ------- ---- ---- ---------------------
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1 Ent_num number 10 1 link to unique listing
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2 Add_num number 10 11 unique record
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identifier
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3 Address text 750 21 street address of SDN
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4 City/ text 116 771 city, state/province, zip/postal code
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State/Province/
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Postal Code
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5 Country text 250 887 country of address
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6 Add_remarks text 200 1137 remarks on address
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END OF ROW 1337
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Alternate identity table, text file name ALT.FF
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Column Posi-
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sequence Column name Type Size tion Description
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-------- ----------- ------- ---- ---- ---------------------
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1 ent_num number 10 1 link to unique listing
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2 alt_num number 10 11 unique record
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identifier
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3 alt_type text 8 21 type of alternate
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identity
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(aka, fka, nka)
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4 alt_name text 350 29 alternate identity name
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5 alt_remarks text 200 379 remarks on alternate
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identity
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END OF ROW 579
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Record separator: carriage return
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null: -0-
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FORMAT SDN CSV
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Main table, text file name SDN.CSV
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Column
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sequence Column name Type Size Description
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-------- ------------ ------- ---- ---------------------
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1 ent_num number unique record
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identifier/unique
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listing identifier
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2 SDN_Name text 350 name of SDN
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3 SDN_Type text 12 type of SDN
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4 Program text 200 sanctions program name
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5 Title text 200 title of an individual
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6 Call_Sign text 8 vessel call sign
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7 Vess_type text 25 vessel type
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8 Tonnage text 14 vessel tonnage
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9 GRT text 8 gross registered tonnage
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10 Vess_flag text 40 vessel flag
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11 Vess_owner text 150 vessel owner
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12 Remarks text 1000 remarks on SDN*
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Address table, text file name ADD.CSV
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Column
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sequence Column name Type Size Description
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-------- ------------ ------- ---- ---------------------
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1 Ent_num number link to unique listing
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2 Add_num number unique record identifier
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3 Address text 750 street address of SDN
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4 City/ text 116 city, state/province, zip/postal code
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State/Province/
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Postal Code
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5 Country text 250 country of address
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6 Add_remarks text 200 remarks on address
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Alternate identity table, text file name ALT.CSV
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Column
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sequence Column name Type Size Description
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-------- ------------ ------- ---- ---------------------
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1 ent_num number link to unique listing
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2 alt_num number unique record identifier
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3 alt_type text 8 type of alternate identity
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(aka, fka, nka)
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4 alt_name text 350 alternate identity name
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5 alt_remarks text 200 remarks on alternate identity
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Record separator: carriage return
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field (value) delimiter: ,
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text value quotes: "
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null: -0-
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*SPILLOVER FILES:
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OFAC has made certain changes to its SDN production system that now allow for
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an unlimited number of identifiers, features and linked to identifications to
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be added to a record. In the fixed-width and delimited files these data are
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stored in the remarks field. Due to these changes, it is now possible for an
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SDN record to exceed the 1000 character remarks limitation. Data that exceeds
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the specified field limit will be truncated to ensure that the current data
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specification is followed. However, in order to ensure that users of these
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files continue to have access to truncated data, OFAC has created "spillover files."
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These files will follow the same data specification of the files they are
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associated with. However, there will be no upper limit on row length in these files.
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The spillover file names are:
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sdn_comments.csv
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sdn_comments.ff
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These files will be listed separately on the OFAC website's SDN page. They will also be listed
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separately in the library/fac_dlim and /fac_delim folders of OFAC's FTP sites.
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Please visit the following tutorial on OFAC's website for more information on
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creating a database using these files:
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https://ofac.treasury.gov/sdn-list-data-formats-data-schemas/tutorial-on-the-use-of-list-related-legacy-flat-files
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THE DISPOSITION OF ALIASES:
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OFAC classifies SDN aliases as weak or strong. In the data files
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discussed in this document, weak aliases are not stored in the alt.* files.
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Weak aliases are stored in the remarks field that trails every primary
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SDN record in the SDN.* files. For more information on weak aliases
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please review the following text taken from the frequently asked questions
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on OFAC's website.
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What are weak aliases (AKAs)?
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A "weak AKA" is a term for a relatively broad or generic alias that
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may generate a large volume of false hits. Weak AKAs include
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nicknames, noms-de-guerre, and unusually common acronyms. OFAC
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includes these AKAs because, based on information available to it, the
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sanctions targets refer to themselves, or are referred to, by these
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names. As a result, these AKAs may be useful for identification
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purposes, particularly in confirming a possible "hit" or "match"
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triggered by other identifier information. Realizing, however, the
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large number of false hits that these names may generate, OFAC
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qualitatively distinguishes them from other AKAs by designating them
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as weak. OFAC has instituted procedures that attempt to make this
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qualitative review of aliases as objective as possible. Before
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issuing this updated guidance, OFAC conducted a review of all aliases
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on the SDN list. Each SDN alias was run through a computer program
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that evaluated the potential of an alias to produce false positives in
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an automated screening environment. Names were evaluated using the
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following criteria:
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Character length (shorter strings were assumed to be less effective in
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a screening environment than longer strings);
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The presence of numbers in an alias (digits 0-9);
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The presence of common words that are generally considered to
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constitute a nickname (example: Ahmed the Tall);
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References in the alias to geographic locations (example: Ahmed the
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Sudanese);
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The presence of very common prefixes in a name where the prefix was
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one of only two strings in a name (example: Mr. Smith).
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Aliases that met one or more of the above criteria were flagged for
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human review. OFAC subject matter experts then reviewed each of the
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automated recommendations and made final decisions on the flagging of
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each alias.*
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OFAC intends to use these procedures to evaluate all new aliases
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introduced to the SDN list.
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Where can I find weak aliases (AKAs)?
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Weak AKAs appear differently depending on which file format of the SDN
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List is utilized.
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In the TXT and PDF versions of the SDN List, weak AKAs are
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encapsulated in double-quotes within the AKA listing:
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ALLANE, Hacene (a.k.a. ABDELHAY, al-Sheikh; a.k.a. AHCENE, Cheib;
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a.k.a. "ABU AL-FOUTOUH"; a.k.a. "BOULAHIA"; a.k.a. "HASSAN THE OLD");
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DOB 17 Jan 1941; POB El Menea, Algeria (individual) [SDGT]
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This convention also is followed in the alphabetical listing published
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in Appendix A to Chapter V of Title 31 of the Code of Federal
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Regulations.
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In the FF, and CSV file formats, weak AKAs are listed in the
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Remarks field (found at the end of the record) of the SDN file. In
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these formats, weak AKAs are bracketed by quotation marks.
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8219@"ALLANE, Hacene"@"individual"@"SDGT"@-0- @-0- @-0- @-0- @-0- @-0-
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@-0- @"DOB 17 Jan 1941; POB El Menea, Algeria; a.k.a. 'ABU
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AL-FOUTOUH'; a.k.a. 'BOULAHIA'; a.k.a. 'HASSAN THE OLD'."
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In the XML version of the SDN List, there is a Type element for each
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AKA. The Type can either be 'weak' or 'strong' (see the XML SDN
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Schema (XSD file) at:
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http://www.treasury.gov/resource-center/sanctions/SDN-List/Documents/sdn.xsd for more
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information).
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Am I required to screen for weak aliases (AKAs)?
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OFAC's regulations do not explicitly require any specific screening
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regime. Financial institutions and others must make screening choices
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based on their circumstances and compliance approach. As a general
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matter, though, OFAC does not expect that persons will screen for weak
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AKAs, but expects that such AKAs may be used to help determine whether
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a "hit" arising from other information is accurate.
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Will I be penalized for processing an unauthorized transaction
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involving a weak alias (AKA)?
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A person who processes an unauthorized transaction involving an SDN
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has violated U.S. law and may be subject to an enforcement action.
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Generally speaking, however, if (i) the only sanctions reference in
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the transaction is a weak AKA, (ii) the person involved in the
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processing had no other reason to know that the transaction involved
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an SDN or was otherwise in violation of U.S. law, and (iii) the person
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maintains a rigorous risk-based compliance program, OFAC will not
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issue a civil penalty against an individual or entity for processing
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such a transaction. |