I don't understand the changes that were apparantly made to the OFAC list late yesterday. Can anyone help?

We are having a hard time staying on-top of the OFAC changes. We ran the list to our customer base before noon yesterday. Do we need to do so again after hearing about changes made late yesterday?

Frankly, we didn't understand it either.

As we note on our OFAC page, they came out with the 27 names on 9/24. Then they added additional descriptive detail on those names on 10/01. They unblocked certain Yugoslavian entities on 10/3, then in the afternoon on 10/3, they came out with another "update" and it appears to indicate that it "updates" the descriptor information they released on 10/01.

The problem is that they did not release a separate issuance that details the updates. Instead, they just updated the overall SDN list and they say "Full details of the
designations can be found on the SDN List or in the SDN Changes List." Since the changes aren't highlighted, we just have chosen to link to the newly updated lists.

In the meantime, they say they will be updating their terrorist brochure today (10/4), so we'll see if we get further enlightenment from that.

We've tried to call OFAC every 15 minutes since the latest change came out and they obviously are stretched extremely thin right now, so we have not yet been able to get through.

I just talked to the OFAC Compliance Office. They realize the recent updates to the list are confusing but they are trying to provide the information as quickly as possible. No names were removed as a result of the most recent update (10-3 pm). If you look closely at the last addition to the SDN Changes starting at the end of page 22 you will note each entry contains (-to-) in the approximate middle of the entry. The information listed after the (-to-)contains the updated descriptor information. In some instances it is another a.k.a. but it may only be an Alt. DOB (alternate date of birth). New names not previously listed are found at the end of the update but all entries should be reviewed due to the updated descriptor information provided on enities that were listed previously.

Whew!! That went over my head. Simple question... If we ran the OFAC list to our customer base effective BEFORE the 3PM change OFAC did, will be safe not to do another one or should we in your opinion?

I think that because some of the updated information they added includes additional aliases, you would need to run the list again.

If it simply included new date of birth (or alternate date of birth information), that would only be relevant in trying to decide if the person you got a "hit" on is the one OFAC is targeting. Since there are actually new names these individuals are known by, however, you should run the list again, because of the chance you may have had transactions with one of the individuals under one of the aliases just added to the list.