OFAC Checks for Car Dealers: What to Know

What OFAC is

OFAC is the Office of Foreign Assets Control, part of the U.S. Treasury. It publishes lists of people, companies and countries that U.S. persons are prohibited from doing business with. The best known is the Specially Designated Nationals and Blocked Persons list, usually called the SDN list.

These rules apply to everyone in the United States, including car dealers. A vehicle sale is a transaction, and a dealer who sells to a blocked person can face serious consequences. This is general information, not legal advice, so talk to an attorney or your lender about your specific obligations.

Why dealers screen customers

Nothing about a used car sale makes a dealer exempt. Finance companies and lenders ask dealers to confirm that customers were screened, and many dealers do it on every deal as a matter of routine. Screening takes a few minutes and creates a record that you checked.

The point is not to interrogate anyone. It is to run the buyer's name through the list before the deal is final, the same way you check the title before you buy a car.

How to run the check

1. Collect the buyer's full legal name from their driver license, and the co-buyer's too
2. Search the name on the SDN list using Treasury's official search tool
3. Review any near matches by comparing address, date of birth and other details
4. Record the date, who ran the check and the result
5. Stop the deal and get advice if you find a real match

Common names produce false matches often. A name match alone does not mean the customer is blocked, so compare identifying details before drawing a conclusion. If you cannot resolve a match, get professional guidance.

The OFAC security statement

Many dealers have the buyer sign a short statement as part of the deal paperwork. It generally says that the customer is not on an OFAC list, that the dealership has checked, and that the customer is not buying the vehicle on behalf of a blocked person.

The statement is not a substitute for running the check. It is a record of what was disclosed and when. Keep it with the signed Buyer's Order in the deal jacket.

What to watch for beyond the list

Export is worth a note. If you sell a vehicle that is likely headed out of the country, ask your attorney what additional requirements apply.

• Buyers who refuse to show ID or give a real name
• Deals where someone other than the buyer is paying and will not identify themselves
• Requests to export the vehicle shortly after purchase
• Insistence on unusual payment arrangements
• Inconsistent details between the ID, insurance and application

Keeping records

A check you cannot prove is a check you did not run. Save a screenshot or printout of the search result, or log the date, name searched and outcome, and file it in the jacket. Keep it as long as you keep the rest of the deal records, and check whether your state or lender wants a longer period.

Make it routine. When screening happens on every deal, at the same point in the process, nobody has to remember. Add it to your deal jacket checklist and review it in your monthly jacket audit.

How a dealer management system helps

DMS Apex prints the OFAC security statement with the deal, alongside the Buyer's Order with your state's required wording, the Buyers Guide in English and Spanish, odometer disclosure, As Is notice and deposit receipt. It handles deals with trade-ins, lien holders and co-buyers, and prints everything in black and white. The statement is a record of disclosure and does not replace running the check itself. DMS Apex covers all 50 states and DC for $28 a month flat, with a 15-day free trial.