Due Diligence and Ongoing Monitoring

My company has a service that we plug company and individual names into (CEO/CFO/ETC) for OFAC data, but we are concerned that the amount of data we receive may not be as robust as some of the alternatives out there. In TPRM we often don't have a lot of private information about the company officers like the CEO/CFO so results on generic names are hard to know if they are relevant or even a proper match to the individuals being searched outside of minor context clues such as location etc. We know that the OFAC website isn't always the most current nor is it as well rounded as the service we use so we don't solely rely on that, but we are hoping to see what others are using for their searches to help get a grasp on how far along we are with the typical industry level searches. Please share what methods you use to conduct your searches and how you may have validated the results for individual and company names. Thank you! 

One strategy I've seen organizations do with OFAC/PEP checks is to simply perform these searches more frequently or use some type of real-time screening tool. There are risk intelligence tools on the market that can help screen for both compliance and reputation risk (e.g., Venmonitor through Venminder). As you mentioned, the OFAC website isn't always current and it may take some time for something to show up, so increasing the frequency can be effective.

In addition to onboarding new vendors and regular re-assessments, some organizations are running OFAC checks on a weekly or monthly basis, or whenever they make a payment. One option is to ask your accounting team for a list of vendors who were paid every week or month and run that through an OFAC search.

As far as validating these results, I would say this relates to your other due diligence efforts. For example, have you validated that these vendors have appropriate compliance policies in place, such as BSA/AML risk assessments? Does the vendor have its own third-party risk management policy that includes OFAC/PEP checks on its vendors? Do they have evidence of internal and external audits? Collecting and reviewing these types of evidence can help show auditors and examiners that your organization is being thorough when conducting vendor due diligence, which includes more than an OFAC check. And if you want to be even more thorough, consider consulting with an attorney or compliance expert who can help determine whether your OFAC checks are appropriate for your business.

I hope these suggestions help and I'm interested in learning how other members are performing these searches.

If your company utilizes Thomson Reuters in any capacity, they offer an add-on package that screens for sanctions including OFAC. Thomson Reuters is essentially the gold standard when discussing background screening, so if you were concerned with the legitimacy / freshness of your results, TR could be a solution.