Build an OFAC sanctions-screening hit interdiction workflow that blocks a matched wire transfer and files the required blocked-property reports

Steps

1. On a confirmed true-positive hit against the SDN or another OFAC list (after manual review clears the fuzzy-match false-positive queue), block the transfer and place the funds in a blocked, interest-bearing account rather than returning them to the originator
2. Escalate the match to your BSA/compliance officer to confirm the interdiction is required and document the determination
3. File the initial report of blocked property within 10 business days of the blocking action, electronically via OFAC's Reporting System (ORS), per 31 CFR 501.603
4. Include the blocked property in the Annual Report of Blocked Property, due September 30 each year, also filed through ORS per 501.603(b)(2)
5. Separately evaluate whether any related transaction should instead be filed as a rejected-transaction report under 31 CFR 501.604, since blocked and rejected reports have different triggers and are distinct filings
6. Retain blocking-action records and filing confirmations for OFAC's required retention period