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OfacScanner

Title, escrow and brokerage

OFAC Check for Real Estate Closings and Escrow

An OFAC check for real estate screens the buyers, sellers and entities in a property deal against the OFAC sanctions lists before funds move through title or escrow. OfacScanner checks each party in seconds and saves a PDF certificate for the closing file.

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At a glance

Who to screen
Buyers, sellers, entities, payees
When
At contract, before disbursement
Time per check
Seconds
Proof
PDF certificate for the closing file
Fits most offices
Starter, $49 a month
Finance manager going through deal paperwork with a customer at dusk

What is an OFAC check in real estate

Real estate deals move large sums, often in a single wire, and the property itself can be a store of value for someone trying to hide assets. OFAC rules prohibit U.S. persons from dealing with blocked persons, and that includes buying from, selling to or disbursing funds for them. Title companies, escrow agents, settlement attorneys and brokerages handle these funds and documents, so they are exposed to the same risk.

An OFAC check in real estate means screening every party who buys, sells or receives money in the transaction. People are checked by name and date of birth. Companies, trusts and other entities that buy property are checked by their legal name, and the people who sign for them are checked too.

Because OFAC liability is strict, a disbursement to a blocked person can lead to a penalty even if nobody knew. A dated record in the closing file shows that the check was done before the money moved.

Parties to screen on a closing

One check per name. Add a date of birth or country when you have it.

  • Buyers

    Every person on the purchase contract.

  • Sellers

    Every owner of record who receives sale proceeds.

  • Buying entities

    The company, trust or partnership taking title.

  • Signers for entities

    Managers, trustees or officers who sign the documents.

  • Payees on the settlement statement

    Anyone else receiving funds, such as a third party lender payoff to a private lender.

  • New parties late in the deal

    An assignment or a change of buyer entity before closing.

Entities and the 50 percent rule

Under OFAC guidance, a company owned 50 percent or more, directly or indirectly, by one or more blocked persons is itself blocked, even when its own name is on no list. OfacScanner screens the names you enter. It does not research who owns an entity. When a limited liability company or trust buys property, finding out who stands behind it and screening those people is part of your own review. Ask for the owners and managers, then screen each of them with the OFAC name search.

How to fit the check into the closing timeline

Two touch points cover most files without adding a day to the deal.

  1. 01

    Screen at opening

    When the order opens, screen the buyer, seller and any entity on the contract. Clear results let the file move on.

  2. 02

    Resolve any Review rating early

    Compare the date of birth, address and nationality with the listed entry and clear namesakes with a reason, days before closing.

  3. 03

    Screen again before disbursement

    Run a second check right before funds go out. The lists change several times a month, and the parties may have changed too.

  4. 04

    File the evidence

    Save the PDF certificates in the closing file. They show the names, rating, list version, user and time.

What title and escrow offices use

Fast single checks

Enter a name and get a rating in seconds, with the alias that matched and the sanctions program.

PDF certificate per party

Ready to print or attach to an electronic closing file.

Search history

Open any past check again when an underwriter or auditor asks.

Batch files for busy offices

On Growth, upload the week of closings as a CSV with batch sanctions screening.

Several users with roles

Growth includes 5 users with Analyst, Reviewer and Admin roles for offices with several closers.

Picking a plan for a real estate office

Starter at $49 a month, or $24 a month billed yearly, fits a single title or escrow office. It includes 1,000 checks a month on the OFAC lists, a PDF for every check, search history and 12 months of audit retention for one user.

Multi office title agencies and brokerages with many agents usually choose Growth at $499 a month, or $249 a month billed yearly. It adds 5 users, batch files, global lists for foreign buyers, case management and 5 years of audit retention. Compare plans on the pricing page.

OFAC screening is separate from other reporting duties that may apply to real estate transfers, such as rules issued by FinCEN. Check those with your counsel or underwriter. OfacScanner is not affiliated with OFAC or the U.S. Department of the Treasury.

Real estate OFAC check questions

Another question? Write to [email protected].

Who should run the OFAC check in a real estate deal?
Usually the title or escrow company that handles the funds, since it disburses money to the parties. Brokerages and settlement attorneys often screen their own clients as well.

Should we screen the seller as well as the buyer?
Yes. The seller receives the sale proceeds, so a blocked seller is as serious as a blocked buyer.

Does OfacScanner find the owners of a buying entity?
No. It screens the names you enter. Identifying owners and applying the 50 percent rule is part of your own review, and each owner can then be screened by name.

Is one check at opening enough?
A second check right before disbursement is safer, because the lists change several times a month and parties can change before closing.

What does the PDF certificate show?
The name screened, the rating, the top candidates and scores, the list version, the user and the time of the check. Read more about each part on the OFAC check page.

Keep exploring

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Screen your first name in seconds

Type a person or company name, see the risk rating and top candidates from the current OFAC list, and keep the evidence when you sign up.

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Results support your compliance decisions, and the final decision stays with your team. OfacScanner is not affiliated with OFAC or the U.S. Department of the Treasury.