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Russian Sanctions & Dealership OFAC Compliance

Apr 18, 2022

Dealerships should be vigilant in their day-to-day compliance with the Department of Treasury’s Office of Foreign Assets Control (OFAC). The United States has imposed economic sanctions on Russia in response to its invasion of Ukraine. The sanctions affects both Russian persons and entities.

The OFAC restrictions prohibit all U.S. persons from engaging in transactions with certain sanctioned countries, governments, or specially designated organizations or individuals (collectively referred to as “prohibited persons”). In the case of individuals and entities identified as terrorists or supporters of terrorism, the sanctions prohibit all U.S. persons from transacting or dealing in any property (or interest in property) of the designated party. The potential penalties for violating the OFAC restrictions can be extremely severe.

Dealerships are reminded of the requirement to check the name of any purchasers or co-purchasers on OFAC’s list of Specially Designated Nationals and Blocked Persons (“SDN List”) on the OFAC website. The SDN List is a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country specific. Collectively, such individuals and companies are called “Specially Designated Nationals” or “SDNs.” Be aware that hundreds of Russian individuals and entities have been added to the SDN List.

In practice, many credit bureaus and agencies have adopted screening software to determine if a person is on the SDN List or any other OFAC sanctions lists. This software matches the person’s name and other information to the names on the OFAC sanctions lists. If there is a potential match, the credit bureaus may place an OFAC “flag” or alert on the report. These systems work differently, but in most cases, they will simply alert the dealer that he or she should verify whether the individual is on one of the OFAC sanctions lists by comparing the dealer’s information to the OFAC information.

NJ CAR recommends that dealerships continue to routinely check the SDN List for purchaser’s and co-purchaser’s names and work with financial institutions to ensure that they are not doing business with individuals on the SDN List. NJ CAR provides the ability to search the SDN List from the member’s portal on the Coalition’s website.

Dealerships should also check the OFAC website directly at:

General information about OFAC compliance and Russian sanctions can be found on its website: