1. What OFAC is
The Office of Foreign Assets Control at the US Treasury administers sanctions programs. Its best-known list is the Specially Designated Nationals and Blocked Persons (SDN) list. US persons — including banks, title companies, closing attorneys and real estate agents — are prohibited from dealing with blocked persons or their property.
2. The 50 percent rule
An entity owned 50% or more, directly or indirectly, by one or more blocked persons is itself treated as blocked — even if it is not named on the list. That is why closing agents ask about the ultimate owners of any company buying property.
3. How screening works at closing
Title companies and banks screen all parties against OFAC lists. Common names can produce false positives, which are resolved with identity documents. A true match means the transaction cannot proceed; funds that belong to a blocked person must be blocked and reported to OFAC, generally within 10 business days.
4. Moving money
Many banks in sanctioned jurisdictions are cut off from the US financial system. Funds normally arrive from an account in the buyer's name at a bank in a third country, with documented lawful origin. Expect enhanced due diligence. No reputable professional will help structure payments to evade sanctions.
5. Beneficial-ownership reporting
Separately from sanctions, federal anti-money-laundering rules require title companies to identify the real owners behind many all-cash purchases by companies and trusts. Miami-Dade, Broward and Palm Beach counties have been covered by such requirements for years, and FinCEN has expanded residential real estate reporting nationally. Plan to disclose who ultimately owns the buying entity.
This guide is general information, not legal or tax advice. Laws and programs change — confirm details with a Florida attorney and a US tax professional.
