BEFORE YOU GET GAS, THE STATION IS REQUIRED BY LAW TO CHECK THE

DON OLDENBURG, WASHINGTON POST - You know this is happening at the
airports, where security pulls some guy out of the boarding line. You've
heard about the feds being on the lookout for money launderers in
high-stakes financial transactions. But a car dealership? Hey, how about
the 7-Eleven? You might be surprised! Alan Dessoff was. Just as Dessoff
was about to sign on the dotted line for a new 2006 Toyota Camry XLE at
Coleman Toyota in Bethesda, the sales manager glanced up from the
printer and casually mentioned that Dessoff wasn't on "The List.". . .

The sales manager told Dessoff that car dealers are required to check
every would-be buyer's name against a computerized list of "thousands of
names." If the name's on The List, no deal. When Dessoff asked where The
List and the requirement to check it came from, the manager, he says,
took on a confidential tone as if passing along a state secret and said,
"the government.". . .

The so-called "Bad Guy List" is hardly a secret. The U.S. Treasury's
Office of Foreign Assets Control maintains its "Specially Designated
Nationals and Blocked Persons List" to be easily accessible on its
public Web site.

Wanna see it? Sure you do. Just key OFAC into your Web browser, and
you'll find the 224-page document of the names of individuals,
organizations, corporations and Web sites the feds suspect of terrorist
or criminal activities and associations. . .

What's not widely known about it is that by federal law, sellers are
supposed to check it even in the most common and mundane marketplace
transactions.

"The OFAC requirements apply to all U.S. citizens. The law prohibits
anyone, not just car dealers, from doing business with anyone whose name
appears on the Office of Foreign Assets Control's Specially Designated
Nationals list," says Thomas B. Hudson, senior partner at Hudson Cook
LLP, a law firm in Hanover, Md., and publisher of Carlaw and Spot
Delivery, legal-compliance newsletters and services for car dealers and
finance companies.

Hudson says that, according to the law, supermarkets, restaurants,
pawnbrokers, real estate agents, everyone, even The Washington Post, is
prohibited from doing business with anyone named on the list. "There is
no minimum amount for the transactions covered by the OFAC requirement,
so everyone The Post sells a paper to or a want ad to whose name appears
on the SDN list is a violation," says Hudson. . .

But The Bad Guy List law (which predates the controversial Patriot Act)
not only is "perfectly ridiculous," it's impractical, says Hudson. "I
understand that 95 percent of the people whose names are on the list are
not even in the United States. And if you were a bad guy planning bad
acts, and you knew that your name was on a publicly available list that
people were required to check in order to avoid violating the law, how
dumb would you have to be to use your own name?"

http://www.washingtonpost.com/wp-dyn/content/article/2006/04/08/
AR2006040800157.html