Further Reading
Chapter 8: Sanctions Screening: Watchlists, False Positives, and Calibration
Essential Reading
OFAC (2019). A Framework for OFAC Compliance Commitments. OFAC's own articulation of the five components of an effective sanctions compliance program. The definitive regulatory statement of what OFAC expects from financial institutions. Free at ofac.treas.gov.
OFAC. Frequently Asked Questions (FAQs)* — Sanctions. OFAC's FAQs provide specific, authoritative answers to common implementation questions including the 50% Rule, voluntary self-disclosure procedures, and reporting timelines. Continuously updated; essential reference for practitioners. Free at ofac.treas.gov.
OFSI (annual). Implementation of Financial Sanctions in the UK. HM Treasury. The UK equivalent of OFAC guidance — OFSI's operational guidance on compliance with UK financial sanctions. Free at gov.uk/government/organisations/office-of-financial-sanctions-implementation.
Wolfsberg Group (2019). Wolfsberg Group Correspondent Banking Due Diligence Questionnaire (CBDDQ). Industry standard questionnaire for correspondent bank due diligence — directly relevant to the correspondent bank risk assessment discussed in Case Study 8.2. Available at wolfsberg-principles.com.
For Practitioners
ACAMS (2022). Sanctions Compliance: A Practical Guide. Comprehensive practitioner guide from the primary AML/sanctions professional body. Covers US, EU, and UK sanctions frameworks and practical implementation guidance.
Morrison Foerster (annual). OFAC Enforcement and Penalty Update. Annual summary of OFAC enforcement actions and penalty calculations — essential for understanding how OFAC applies its framework in practice. Free at mofo.com.
Gibson Dunn (annual). Year-End Sanctions Update. Law firm annual review of US sanctions developments, enforcement trends, and compliance implications. Free at gibsondunn.com.
Sullivan & Cromwell. OFAC and Sanctions Enforcement and Compliance. Practitioner-focused analysis of OFAC enforcement practice and compliance program design. Available via the firm's publications.
For the Curious
Zarate, J. (2013). Treasury's War: The Unleashing of a New Era of Financial Warfare. PublicAffairs. First-person account from the architect of the US post-9/11 financial sanctions strategy. Provides essential context for why the current sanctions regime is structured as it is and how it has evolved into a primary tool of US foreign policy.
Tooze, A. (2018). Crashed: How a Decade of Financial Crises Changed the World. Penguin. Broader economic history that contextualizes the role of the US dollar in global finance — essential background for understanding why OFAC sanctions have such disproportionate global impact.
Farrow, R. (2018). War on Peace: The End of Diplomacy and the Decline of American Influence. W.W. Norton. A critical perspective on the use of economic sanctions as a foreign policy tool — the diplomatic counterpoint to Zarate's financial warfare argument.
Hufbauer, G.C., Schott, J.J., Elliott, K.A., & Oegg, B. (2007). Economic Sanctions Reconsidered (3rd ed.). Peterson Institute for International Economics. The authoritative academic assessment of the effectiveness of economic sanctions as a foreign policy tool — an important counterpoint to the compliance-centric perspective.
Regulatory Primary Sources
| Document | Jurisdiction | Key Relevance |
|---|---|---|
| 50 USC §1705 | US | IEEPA — primary OFAC authority |
| 50 USC §1702 | US | President's sanctions powers |
| 31 CFR Parts 500–599 | US | OFAC's sanctions program regulations (country/program specific) |
| 31 CFR Part 501 | US | OFAC reporting, recordkeeping, and penalties |
| The Sanctions and Anti-Money Laundering Act 2018 | UK | UK sanctions authority post-Brexit |
| The Russia (Sanctions) (EU Exit) Regulations 2019 | UK | UK Russia sanctions (principal example) |
| Council Regulation (EU) 833/2014 (as amended) | EU | EU Russia sanctions |
| UNSCR 1267 (1999) + successor resolutions | International | Al-Qaida/Taliban sanctions regime |
| UNSCR 2270 (2016) + successor resolutions | International | DPRK (North Korea) sanctions regime |
| SWIFT Customer Security Programme | International | SWIFT security requirements affecting sanctions screening integration |
Technology References
| Category | Vendors/Tools |
|---|---|
| Sanctions Screening Platforms | |
| Accuity (now Firco) | Dedicated sanctions screening platform — market leader |
| LexisNexis Risk Solutions | Sanctions screening + adverse media |
| Dow Jones Risk & Compliance | Watchlist data + screening |
| ComplyAdvantage | AI-driven financial crime screening |
| Watchlist Data Providers | |
| Refinitiv World-Check | Comprehensive PEP + sanctions data |
| LSEG (London Stock Exchange Group) | Post-merger successor to Refinitiv |
| Dow Jones Factiva Risk | Alternative data source |
| Correspondent Banking | |
| SWIFT Compliance Analytics | Correspondent bank due diligence data |
| KYC Registry (SWIFT) | Standardized correspondent bank KYC data |
Note: Vendor listings are for reference only, not endorsements. Pricing and product positioning changes frequently in this market.
Professional Standards
OFAC's Compliance and Enforcement Resources — ofac.treas.gov — The authoritative source for all US sanctions compliance practitioners, including updated SDN List, enforcement actions database, and guidance documents.
Wolfsberg Group Principles — wolfsberg-principles.com — Industry consortium guidance specifically on financial crime compliance including sanctions.
ACAMS CGSS (Certified Global Sanctions Specialist) — The primary professional certification focused on sanctions compliance. acams.org.