For Entertainment Purposes Only: SDN Search

On December 7, 2011, OFAC debuted its own online SDN Search Tool.

Accompanying the tool is a formidable disclaimer (I've taken some liberties):

“This SDN Search application (“SDN Search”) is designed to facilitate the navigation of the Specially Designated Nationals and Blocked Persons list (“SDN List”).

SDN Search uses literal character matching logic to identify exact matches between word or character “strings” exactly as entered into SDN Search, and any name or other information exactly as it appears on the SDN list.

SDN Search will not detect misspellings or other incorrectly entered text, and will not return near matches to, or other variations of, the entered text.

SDN Search may suddenly accelerate to dangerous speeds.

Discontinue use of SDN Search if any of the following occurs:

• itching
• vertigo
• dizziness
• tingling in extremities
• loss of balance or coordination
• slurred speech
• temporary blindness
• profuse sweating
• heart palpitations

Do not taunt SDN Search.

Use of this system implies understanding that searches performed by SDN Search are conducted at the user’s own risk, and that the search results provided by SDN Search do not represent an official confirmation by the Office of Foreign Assets Control or the Department of the Treasury of the existence or absence of a match between any information entered by the user and any information contained on the SDN List.

The use of SDN Search does not limit or excuse any liability for any act undertaken as a result of, or in reliance on, such use.”

Donning appropriate safety gear; I tested my favorite SDN “Daytona Pools, Inc.” with some variations.

The listing:

“DAYTONA POOLS, INC., 225 Syracuse Place, Richardson, TX 75081

[LIBERIA]”

Target Text	Hit?
Daytona Pools	Yes
Daytona Pools Incorporated	No
Daytonapools	No
Daytona*Pools	No
Dayt0na Pools	No
Daytona Poo1s	No
Daytona Pool	Yes
Dayton A Pools	Yes
Daytona Polos	No
Daytona Poods	No
Dayton A Polos	No

In addition to misspellings, near matches or mistakes in data entry warned about in the disclaimer, SDN Search does not recognize “glued names” (Daytonapools) or fully elaborated names (Daytona Pools, Incorporated.) These 2 variations have been featured in recent OCC tests of OFAC screening tools.

With all of the limitations of the SDN Search tool (both in search mechanics, and 'fitness for decision-making') it's hard to imagine an operational, 'prime-time' use for this tool.