The Office of Foreign Assets Control (“OFAC”) has just debuted a new web page which features a facility allowing users to search OFAC’s Specially Designated Nationals and Blocked Persons list. Go to that new page by clicking here. Put in a name and it quickly spits out the results. You can even export those results to an Excel spreadsheet. The page worked perfectly on my Android phone in case you need to consult the SDN list while on the run.

But before you get too excited there is a major limitation. As the hilariously prolix disclaimer attached to the site notes, all searches are literal. No close matches are returned. Misspelled names won’t yield any results. This is a big deal since a large number of the names on the list are roman character transliterations from the Arabic and Persian where there is no agreed convention on transliteration.

Let’s just pull an example that immediately comes to mind like . . . say . . . Khadaffi. Enter that last name and you get no results, even though there are members of the Khadaffi family that are alike, kicking and still on the SDN list. In all fairness, ABC News reports that there are more spellings of the notorious family name than you can shake a stick at.

Beyond that, the lawyers have gotten to the page with an OFAC version of the “don’t try this at home, kids” disclaimer:

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.

In other words, use at or own risk and if the site misses a match, well, that’s your problem and OFAC reserves the right to fine you $250,000 anyway. Even if the mistake was OFAC’s fault.

This is not much different from the ridiculous disclaimer that OFAC prints each time it prints a new version of the SDN list in the Federal Register:

The list published as Appendix A is not definitive or all-inclusive, and new or updated information may be added to OFAC’s Web site and published in the Federal Register at any time. U.S. persons or persons subject to U.S. jurisdiction, depending on the sanctions program, are advised to check the Federal Register and the most recent version of the SDN List posted on OFAC’s Web site for updated information on designations and blocking actions before engaging in transactions

So even with the printed SDN list, OFAC has to tell you that you can’t rely on it and that you can’t engage in any transaction without searching the last century of the Federal Register all the way back to the first issue in 1936 to see if a party was designated by OFAC but inadvertently left off the SDN list. Right.

(For a humorous rewrite of the search site disclaimer, go read Scott Kinney’s blog post on it.)