Real-estate escrow sits at one of the highest-risk intersections in OFAC compliance: large transactions, multiple parties, tight settlement timelines, and a professional services exemption that many firms interpret too broadly. OFAC has been explicit: escrow officers, title companies, and real-estate attorneys must screen all parties to a covered transaction — buyers, sellers, lenders, and beneficial owners — before funds are disbursed.
The operational challenge is doing this systematically when every deal has a different cast of parties and a closing date that does not move for compliance.
A six-step workflow that holds up under examination
- Step 1 — Collect: gather full legal names, dates of birth (individuals), and entity identifiers for all transaction parties at contract execution.
- Step 2 — Screen: run every party through current OFAC SDN, EU, UN, and UK OFSI lists at minimum.
- Step 3 — Adjudicate: for any match above your threshold, assign the alert to a named reviewer for a clear or confirm decision within one business day.
- Step 4 — Document: retain the screening results, the adjudication decision, and the reviewer’s name in the transaction file.
- Step 5 — Re-screen at closing: run a final screen no more than 24 hours before disbursement to catch any new designations.
- Step 6 — Archive: store the complete screening record for the statutory retention period (five years minimum for most regulated entities).
VeriSanction’s workflow module is designed specifically for this pattern: screen at intake, schedule a re-screen reminder before closing, and produce a one-page transaction compliance summary that goes into the file. The whole process takes under five minutes per transaction and produces a record that satisfies OFAC examination standards.