In October, OFAC released new guidance for handling false positive identifications to parties on restricted party lists. The guidance urges care by those who use “false hit lists” to track and automatically clear parties that are determined to not be a listed party after an initial positive match. It states: “While false hit lists represent a common and legitimate practice, and are generally designed to reduce the volume of OFAC-related matches that a US person has determined are false, it is important that each US person implement policies and procedures designed to review, evaluate, and reassess the parties that are included on such lists.” The guidance further provides recommended best practices for maintaining false hits lists.
