OFAC Potential Match Investigation Form

Use it when screening produces a possible OFAC sanctions match and you need to document the investigation before clearing or blocking the record. It is meant for case-by-case review, not routine onboarding data entry. If the alert is clearly unrelated, you may not need a full investigation record. If the match is uncertain, this form creates the audit trail that supports the final decision.

A compliance analyst, sanctions reviewer, or other authorized reviewer should complete it, with escalation to legal or the sanctions officer when required. The person filling it out should be able to compare identifiers, review source records, and explain the rationale for the outcome. If your process separates screening from adjudication, this form should capture both the initial review and any escalation. Keep the reviewer role explicit so the audit trail is clear.

It is used each time a screening alert generates a potential OFAC match that requires manual review. That can happen during onboarding, periodic rescreening, payment review, vendor setup, or ad hoc investigations. The form is not a recurring checklist by itself; it is a case record for one alert or one matched party. If your workflow creates multiple alerts for the same entity, you may want a linked case ID or source record reference.

Compare the identifiers that actually help distinguish the screened party from the OFAC entry, such as full name, aliases, address, date of birth where lawful and necessary, country, registration numbers, and other available reference data. Use only the minimum necessary fields and avoid collecting extra PII that does not change the decision. The goal is to show why the match is true, false, or inconclusive. If a field is unavailable, note that explicitly rather than leaving the reviewer to guess.

No. It is designed to capture the audit trail inside the case record, including who reviewed the alert, what evidence was checked, what escalation occurred, and why the final decision was made. If your organization uses separate logs or case management notes, this form should reference them through the source record reference or audit trail notes. A clean audit trail is especially important when a decision is later questioned. Keep timestamps, reviewer names, and document references consistent with your internal controls.

Clearing means the reviewer determined the potential match is not the sanctioned party or does not require blocking under your policy. Blocking means the record or transaction was restricted according to the applicable sanctions process. The form should make the final decision unambiguous and include the rationale and any blocking action taken. If the decision is pending escalation, do not force a clear-or-block outcome before the review is complete.

Attach only the documents needed to support the decision, such as screening screenshots, identity verification records, correspondence, or internal notes. Avoid uploading unnecessary PII or unrelated files, especially if they are not needed for the case record. If your process uses progressive disclosure, keep the main form concise and attach evidence only when it changes the outcome. Make sure file naming and retention follow your internal records policy.

You can add conditional logic for alert type, entity type, or escalation path so reviewers only see the fields that apply. For example, payment screening cases may need different evidence than vendor onboarding cases. You can also adjust the decision options, required supporting documents, and next review date rules to match your policy. Keep the core structure intact so every case still captures the alert, comparison, due diligence, escalation, and outcome.

Ad hoc notes often miss the alert ID, the exact identifiers compared, or the reason a match was cleared. They also tend to skip escalation details and make it hard to reconstruct the decision later. Without a standard form, reviewers may collect too much data in one case and too little in another, which weakens consistency. This template gives you a repeatable structure so each review is documented the same way.