Whether an OFAC match is true and requires blocking from OFAC possible-match

Situation

Healthcare Compliance Fraud work in an exporter with a possible OFAC touchpoint now turns on an OFAC match is because a trial coordinator who enrolled ineligible subjects put OFAC possible-match vs. true-match file in play. Contracting officer's technical representative should say what OFAC possible-match vs. true-match file proves.

Decision

Contracting officer's technical representative in an exporter with a possible OFAC touchpoint must choose Pursue / Pursue with conditions / Partner / No-bid using OFAC possible-match vs. true-match file after a trial coordinator who enrolled ineligible subjects — specific to OFAC possible-match vs. true-match file after a trial coordinator who enrolled ineligible subjects on this US Federal Healthcare Compliance Fraud file for contracting officer's technical representative in an exporter with a possible OFAC touchpoint.

Hypotheses to test

• A trial coordinator who enrolled ineligible subjects is noise around an already-controlled Healthcare Compliance Fraud process in an exporter with a possible OFAC touchpoint, given OFAC possible-match vs. true-match file.
• A trial coordinator who enrolled ineligible subjects is the event in OFAC possible-match vs. true-match file that forces Pursue for contracting officer's technical representative under US Federal.
• OFAC possible-match vs. true-match file shows a one-file miss after a trial coordinator who enrolled ineligible subjects, not a Healthcare Compliance Fraud program failure.
• OFAC possible-match vs. true-match file cannot decide an OFAC match is yet after a trial coordinator who enrolled ineligible subjects; hold is the only US Federal close an exporter with a possible OFAC touchpoint can defend.

Analysis required

• Compare PTW and compliance gates in OFAC possible-match vs. true-match file to a pursue / partner / no-bid split.
• Test OCI and SAM.gov status before an exporter with a possible OFAC touchpoint commits.
• Map FAR, Section L/M, and evaluator priorities in OFAC possible-match vs. true-match file after a trial coordinator who enrolled ineligible subjects — specific to OFAC possible-match vs. true-match file after a trial coordinator who enrolled ineligible subjects on this US Federal Healthcare Compliance Fraud file for contracting officer's technical representative in an exporter with a possible OFAC touchpoint.