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Real Estate & Title

OFAC Screening for Real Estate & Title Companies

Title companies and settlement agents must screen all parties in real estate transactions against OFAC.

Title companies, escrow agents, and real estate firms are subject to OFAC regulations and must screen all parties involved in real estate transactions. OFACScreen provides the screening tools and documentation you need for every closing.

Use Cases

How Real Estate & Title Use OFACScreen

1

Title Searches

Screen buyers, sellers, and all parties named in the transaction as part of your title search process.

2

Settlement & Closing

Run OFAC screening on all parties at settlement, including agents, attorneys, and beneficial owners.

3

Commercial Transactions

Screen entities, beneficial owners, and foreign nationals involved in commercial real estate deals.

4

FinCEN GTO Compliance

Screen parties in transactions covered by Geographic Targeting Orders for additional OFAC risk.

The Requirement

What OFAC Asks of Real Estate & Title

The shell company is not the party to screen

A shell company will not appear on the SDN List. Its beneficial owner might. Screening the entity name and stopping there is how a sanctioned buyer gets through a closing.

Geographic Targeting Orders already ask for the names

Since 2016 FinCEN has issued GTOs requiring title insurance companies to identify the natural persons behind shell companies buying residential real estate in named metropolitan areas.

Screen again before you disburse

A final screen before funds are released catches designations made between opening the file and closing it. If it looks like a true match, stop the transaction and do not tell the parties why. OFAC rules prohibit tipping off.

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