Sanctions screening for every party at the closing table.
Who checks the buyer, the seller and the entity behind them on your closings today? MoneyWave Compliance is a pre-closing review for title insurance agencies, settlement agents and closing attorneys: small offices, from a single closer to a team of fifteen, that carry sanctions liability without a compliance department.
| Party | KYC | OFAC SDN | OFAC Consolidated | PEP | Adverse media |
|---|---|---|---|---|---|
Party A Individual · Seller | Verified | Clear | Clear | Clear | Clear |
Party B Entity · Buyer · 2 beneficial owners | Verified | Clear | Clear | Clear | Clear |
Party C Individual · Beneficial owner of B | Verified | Candidate | Clear | Clear | Clear |
Strict liability, no exception, and no one at the table checking.
- I.
OFAC liability is strict.
Knowledge is not required and there is no small-business exception. Every U.S. person, including every title company, is prohibited from dealing with parties on the SDN List.
- II.
A typical closing is not screened.
Residential closings routinely proceed without any sanctions check of the buyer, the seller, or the entity behind either of them. There is no record that a check was run, because none was.
- III.
Bank-grade tools carry bank-grade budgets.
Screening platforms built for financial institutions assume a compliance team, an integration project and a contract sized for a bank. A closing office has none of those.
One review of every party before a file closes.
Four functions. Each one produces a record you can hand to an examiner.
Party registry
Individuals and legal entities on a transaction, with identity verification status and, for entities, a structured register of beneficial owners.
Screening
Parties screened against OFAC SDN, the OFAC Consolidated List, PEP data and adverse media. Potential matches are scored and queued for a human analyst. Software never decides alone.
Reportability
Deal-level evaluation of the conditions described in 31 C.F.R. § 1031.320, with a documented determination and filing deadline where an applicable reporting obligation is in effect.
Audit trail
Every source queried, every result returned, every analytical step, preserved for regulatory examination.
MoneyWave Compliance is a due-diligence and fraud-prevention tool. It is not a consumer reporting agency product and must not be used for employment, credit, insurance, or tenant screening. Every generated report carries a binding-use disclaimer.
A deterministic verdict, a human confirmation, and a report that cannot skip a step.
No candidate matches. All parties verified. Report may issue.
A candidate match is waiting for an analyst. Report is held.
A match is confirmed. The file does not proceed.
- The verdict is code, not opinion.
- The verdict policy is deterministic. The same facts produce the same verdict every time, and the rule that produced it can be read and audited.
- A language model does one job: telling a match from a namesake.
- When a name hits a list, the model compares dates of birth, nationalities and other identifiers to separate a true sanctions match from a person who merely shares the name. It never sets the verdict.
- A person confirms every match.
- Every potential match is presented as a candidate. An analyst confirms or dismisses it, and that decision is recorded with their name and the time.
- No report until KYC, screening and beneficial ownership are closed.
- The pre-closing risk report cannot be issued while any party is unverified, any screening result is unresolved, or any entity is missing its owners.
Where the rules stand.
31 C.F.R. § 1031.320 (FinCEN Residential Real Estate Rule) was vacated by the U.S. District Court for the Eastern District of Texas on 19 March 2026 (Flowers Title Companies, LLC v. Bessent). FinCEN appealed to the Fifth Circuit on 11 May 2026. While that order remains in force, reporting persons are not required to file Real Estate Reports and are not subject to liability for failing to do so.
Sanctions obligations are independent of that rule. Every U.S. person, including every title company, is prohibited from dealing with parties on the OFAC SDN List, and that liability is strict.
A statement of status as of the date on this page, not legal advice. Consult counsel about your obligations.
- 19 Mar 2026Rule vacatedU.S. District Court, E.D. Texas · Flowers Title Companies, LLC v. Bessent
- 11 May 2026Appeal filedFinCEN · U.S. Court of Appeals for the Fifth Circuit
- OngoingOFAC obligations in forceIndependent of the rule · strict liability for every U.S. person
Working with a small number of agencies while the platform is built.
What the pilot includes
- Access to the party registry, screening queue and reportability workflow
- Setup and onboarding conducted by email
- A named contact on our team for the duration of the pilot
What we ask of your agency
- Run a handful of closings through the workflow alongside your current process
- Tell us where it slows you down or asks for something you do not have
What your agency gets
- A documented screening record for every party you run
- A direct say in what gets built next
- First access when the platform becomes generally available
Tell us about your agency.
Every request is answered by email.