Screen a payment against the OFAC SDN list

Reinforce OFAC screening from bank-compliance training. A true match is not paid. Blocked property is reported within 10 business days, and the customer is not tipped that a sanctions hit occurred.

1. Run the payment parties through the current SDN and consolidated lists.
2. Work possible matches against the taught identifiers.
3. Escalate a true or unresolved match to the sanctions officer.
4. Block or reject the payment as that officer directs.
5. Place blocked funds in an interest-bearing blocked account if the program requires blocking.
6. File the blocked-property or reject report with OFAC within 10 business days.
7. Do not tell the customer they were sanctioned.
8. Do not process the payment around the hit.