OFAC

OFAC (Sanctions) Screening & Barred Parties

The Legal Obligation No AP Function Can Delegate OFAC sanctions operate on strict liability. Ignorance of a vendor's sanctioned status is not a defense. For accounts payable, this means that screening against the SDN list and all applicable international watchlists is not a best practice — it is a legal duty that attaches before the first payment is authorized. Accounts payable sits at the terminal point of the disbursement cycle — the moment at which an obligation becomes a payment and orga