OFAC requirements for credit unions come down to three duties: screen every member, joint owner, beneficiary and payment counterparty against the OFAC sanctions lists, block and report any match to OFAC within 10 business days, and keep a dated record of each check for 10 years. There is no size exemption, and screening done by your corporate credit union on wires does not cover your OFAC obligations for the rest of the membership. A small credit union that adds a few hundred members a month can meet the requirement for $24 to $50 a month. One that rescreens its whole membership file after every list update usually pays $250 to $500 a month for software that does it automatically.
Below we compare the options a BSA officer, compliance manager or CEO of a credit union is likely to shortlist: the screening built into your core, the screening your corporate credit union runs on wires, a full BSA and AML suite, a direct competitor, our own product and the free Treasury search. Prices come from public vendor pages in October 2026. They change, so confirm them before you sign anything.
OFAC screening options compared for credit unions
| Option | Entry price | What it screens | Lists | Record for the exam file | Rescreening of the membership |
|---|---|---|---|---|---|
| OfacScanner Starter | $49 a month, or $24 a month billed yearly | 1,000 checks a month, 1 user | OFAC SDN and Consolidated | PDF certificate per check with list version, time and user | No, you run checks again by hand |
| OfacScanner Growth | $499 a month, or $249 a month billed yearly | 50,000 checks a month, 5 users, CSV upload | OFAC plus UN, EU, UK, Canada and Australia | PDF per check plus a case with the reviewer's decision and reason | Yes, up to 50,000 saved members after every list update |
| OFACScreen | $49 a month (Starter), $149 (Professional), $349 (Business) | 1,000, 2,000 or 10,000 searches, 3 to 25 users | 14 lists on every plan | Free PDF records on every plan | 10, 50 or 500 names checked daily |
| Screening inside your core processor | Usually a module or add on, priced by your core contract | New accounts and sometimes ACH or wires | Usually OFAC, ask which lists | Ask whether a single check can be exported with a date | Varies, ask how often the full file runs |
| Corporate credit union wire screening | Bundled with wire services | Wires that pass through the corporate | OFAC | Held by the corporate, not in your file | No, it only sees payments |
| BSA and AML suites | Quote only | Members, transactions, alerts, case work | Sanctions plus PEP and often adverse media | Case records in the platform | Yes |
| Treasury Sanctions List Search | Free government website | One name at a time | OFAC lists only | None, you print or screenshot it | No |
Two honest takeaways. A larger credit union that already runs a BSA suite for suspicious activity monitoring probably has sanctions screening inside it and does not need us, unless that module is priced as an expensive add on. A credit union with fewer than 50,000 members that relies on the core check at account opening usually has two gaps an examiner will notice: no proof of the check in a form you can hand over, and no rescreening of existing members when OFAC adds names. Growth fills both gaps for $2,988 a year. If you serve a few hundred members a month and rescreen by exporting your file, Starter or OFACScreen Starter is enough.
What are the OFAC requirements for credit unions
OFAC rules apply to every U.S. person, and every federally insured credit union is one. NCUA examines OFAC compliance as part of the BSA examination, using the FFIEC BSA/AML Examination Manual. The duties that matter day to day are these.
- Do not deal with a blocked person. You may not open an account for, lend to, or process a payment for anyone on the SDN list, or a company 50 percent or more owned by blocked persons, unless OFAC has issued a license.
- Block or reject, then report. Funds belonging to a blocked person go into a blocked, interest bearing account and are reported to OFAC within 10 business days. Rejected transactions are reported within 10 business days too. All blocked property is reported each year by September 30, as of June 30. Since August 2024 these reports go through the OFAC Reporting System.
- Keep the records. The 2024 change to the sanctions statute of limitations moved the retention period to 10 years. Our guide to OFAC recordkeeping requirements lists what that covers.
- Have a written program and train staff. Examiners expect a risk based OFAC program approved by the board, a named person responsible for it, and training for the staff who open accounts and send payments.
Liability is strict. A wire sent for a blocked member is a violation even when nobody knew. What lowers a penalty in practice is showing that you followed a reasonable written program. That proof is your screening record.
Does my corporate credit union's OFAC screening cover us
No, not for everything. Corporate credit unions screen the wires and some ACH files that pass through them, and that protects the payment in flight. It does not screen your membership, your loan files, your share certificates or the people who sign on a business account. Corporates say this themselves: Alloya's 2026 statement of BSA and OFAC compliance notes that its screening does not relieve member credit unions of their own OFAC responsibilities. Treat the corporate check as one layer and keep your own record for everything else.
Who should a credit union screen
- New members and joint owners, at account opening, before funds are accepted.
- Beneficiaries, trustees and authorized signers, including powers of attorney added later.
- Business members and their beneficial owners, the people who own 25 percent or more and the person who controls the company. Before you open a business account, a company background check shows whether the business is real and active, and the owners it names are the people you then screen.
- Borrowers, co signers and guarantors, including indirect auto loans that come in through dealers.
- Wire and international ACH counterparties, both senders and receivers. Our payment screening page covers that workflow.
- Vendors, from the core provider to the collection agency. The OFAC vendor screening page shows how to run the AP file in one upload.
When should a credit union run an OFAC check
At four moments: at account opening, before every wire and international ACH, when a loan is booked, and after each OFAC list update for the whole membership. The last one is where most small programs fall short. OFAC changes its lists several times a month, and a member cleared in March can be designated in June. Running 20,000 members through the Treasury search by hand is not possible, which is why ongoing sanctions monitoring rechecks saved members after each update and alerts only on new possible matches. A monthly export of your membership file uploaded to batch sanctions screening is the cheaper middle ground if you do not want automatic rescreening.
Is the OFAC check in our core processor enough
Sometimes it is. Most cores run an OFAC check when an account is opened, and some also screen ACH and wires. Ask your core provider four questions before you rely on it alone. Which lists does it check, and how soon after an OFAC update is the list refreshed? Does it rescreen existing members, and how often? Can you pull a dated record of one check for one member when an examiner asks? Does it cover the names that live outside the core, such as indirect lending, vendors and loan participations? If any answer is no, keep the core check for account opening and add a separate tool for the record and the rescreening. That combination is common, and examiners do not object to it as long as your written program says which system does what.
How much OFAC screening costs a credit union
| Credit union profile | Typical need | Plan | Yearly cost |
|---|---|---|---|
| Under 5,000 members, a few dozen new accounts a month | OFAC check per new member and per wire with a PDF for the file | OfacScanner Starter | $288 |
| 5,000 to 50,000 members, rescreening after list updates | Saved membership file rechecked automatically, cases with reviewer notes | OfacScanner Growth | $2,988 |
| Real time screening of digital account opening and payments through an API | API and webhooks connected to the online banking or account opening platform | OfacScanner Scale | $11,988 |
| Full BSA program with transaction monitoring and SAR case work | A BSA and AML suite | Vendor quote | Usually five figures or more |
Prices for every plan are on our pricing page. Every plan is sold month to month or yearly at about half the monthly rate, with no setup fee.
How to handle an OFAC hit at a credit union
Most hits are false positives: a common name, a partial match or a different date of birth. Compare the identifiers you hold (date of birth, address, ID number, nationality) with the listed entry. If they clearly differ, clear the hit and write down why. If they match or you cannot rule the entry out, stop the transaction, confirm against the official Treasury Sanctions List Search, escalate to your BSA officer and call the OFAC hotline if you are still unsure. Our SDN list search page shows how a score breaks down by name, alias and identifiers, which makes the clear or escalate decision faster.
What to ask before you buy OFAC software for a credit union
- Can we upload the whole membership file as a CSV, and how long does a 30,000 row file take?
- Are saved members rescreened automatically after every OFAC update, and do we only see new possible matches?
- Does every check save a dated record with the list version that we can hand to an NCUA examiner?
- How many staff logins are included, and can each reviewer's decision be traced to a name?
- Which lists are included besides OFAC, in case members send funds to the UK, EU or Canada?
- Is there a monthly option, or does the vendor require a multi year contract?
Our pick for credit unions
For a credit union under about 50,000 members that wants proof and rescreening without buying a full BSA suite, Growth is the plan we would choose: it screens the full file in one upload, rechecks every saved member after each list update and records who cleared each hit and why. A very small credit union with one compliance person can start on Starter and move up when rescreening becomes a priority. Try a member name in the OFAC search console first, open the PDF it produces and decide whether it is the record your examiner would want to see. For the broader picture, see our sanctions screening for banks and credit unions page and the OFAC compliance software overview.