Noble Sight
The name changed. The phone number didn't.
A California freight forwarder arranged a $5,950 shipment from a Chinese supplier OFAC had designated four months earlier. The supplier had renamed itself. Pegasus checked the new name against the SDN list and got nothing. The phone number on the shipping documents and the email address Pegasus was writing to were on the SDN entry the whole time. This page walks the document trail OFAC describes, and runs each step as a Noble request, including the one that comes back empty.
Source: ofac.treasury.gov/media/937206/download (PDF, 5 pages). Every quotation below is verbatim from that document. Part of Noble's enforcement series.
Pegasus Worldwide Logistics (“Pegasus”), a California-based logistics company and freight forwarder, has agreed to pay $175,015 to settle its potential civil liability for apparent violations of OFAC counter narcotics sanctions, as well as OFAC reporting obligations. The apparent violations occurred when Pegasus arranged for the shipment of equipment from a designated supplier in China and failed to identify the equipment as such due to substantial deficiencies in its compliance review and program.
Enforcement Release, page 1. Pegasus is "a small integrated logistics company of about a dozen employees" (page 1).
KEY to a Noble API key. A free-tier key works; keys are invite-only while Noble is in beta (sales@noblesight.io). The identifiers below are the ones OFAC published on the SDN entries; they are public record.
- 2023-05-30OFAC designates Youli Technology Development Co., Ltd. with "several additional identifiers, including its phone number and email address." Youli renames itself Huizhou Youli Fushi Co., Ltd. Its identifiers do not change.
- 2023-09-12Pegasus instructs Youli, "via communication with an email address identified as associated with Youli on the SDN List", to arrange the shipment.
- 2023-09The shipping documents name the shipper by its new name and carry "Youli's unchanged telephone number as OFAC identified it on the SDN List." Pegasus files the Importer Security Filing with CBP from them.
- Just before departurePegasus screens the new name against the SDN List. Null response. Nobody screens the phone number or the email.
- 2023-11-03CBP detains the machine and names OFAC as the responsible agency. Pegasus pays the import duties anyway. CBP seizes the machine on 2023-12-06.
Screen the new name, and get what Pegasus got
Upon its designation, OFAC added Youli to the SDN List and included several additional identifiers, including its phone number and email address. After its designation, Youli changed its name to Huizhou Youli Fushi Co., Ltd.
After receiving the shipping documents from the Chinese shipping agent, pursuant to its policy, Pegasus performed rudimentary manual sanctions screening by checking “Huizhou Youli Fushi Co., Ltd,” against the SDN List, which resulted in a null response.
Enforcement Release, pages 1 and 2.
What failed
Nothing, yet. A renamed entity is a different string, and no name-matching engine should claim otherwise. The failure is in what was not screened. Noble's answer to this request is honest about it.
Noble's answer
The new name scores 36 against the old entry: no_significant_match, no alert. That is the correct answer to the question asked. The page exists because the question was too narrow.
Run it
curl -s -X POST https://api.noblesight.io/v1/screen -H "X-API-Key: $KEY" -H "Content-Type: application/json" -d '{"name":"Huizhou Youli Fushi Co., Ltd","lists":["ofac"]}'
The fields: summary.verdict, alert_id
"alert_id": null,
"summary": {
"verdict": "no_significant_match",
"top_match": { "uid": "41376", "name": "YOULI TECHNOLOGY DEVELOPMENT CO., LTD.", "score": 36.1 }
}
Captured from production on 2026-10-23, engine 2.4.0. The old entry is the top candidate, at a score that would never alert. Pegasus's "null response" and Noble's 36 are the same answer.
Screen the phone number on the shipping document
Those documents identified the shipper using Youli’s new post-designation name, “Huizhou Youli Fushi Co., Ltd,” but included Youli’s unchanged telephone number as OFAC identified it on the SDN List.
Enforcement Release, page 2.
What failed
The number was in Pegasus's hands, on the document it used to file with Customs. Its own policy said to screen "parties’ name, address, email, phone, and other information". Nobody did.
Noble's control
An identifier is a first-class input to POST /v1/screen, not an afterthought. Every identifier OFAC publishes on an entry, including phone numbers, email addresses, websites and registration numbers, is indexed and matched exactly. A hit on an identifier scores 100 and names the identifier it matched in matched_via.
Run it
curl -s -X POST https://api.noblesight.io/v1/screen -H "X-API-Key: $KEY" -H "Content-Type: application/json" -d '{"ids":[{"number":"8615815351839"}],"lists":["ofac"]}'
The fields: matches[].score, matches[].matched_via
"summary": { "verdict": "confirmed_match" },
"matches": [
{ "uid": "41301", "score": 100, "last_name": "GUO", "first_name": "Chunyan", "sdn_type": "Individual", "programs": ["ILLICIT-DRUGS-EO14059"], "prohibition_type": "blocking", "matched_via": [{ "number": "8615815351839" }] },
{ "uid": "41356", "score": 100, "last_name": "GUO", "first_name": "Ruiguang", "sdn_type": "Individual", "programs": ["ILLICIT-DRUGS-EO14059"], "prohibition_type": "blocking", "matched_via": [{ "number": "8615815351839" }] },
{ "uid": "41357", "score": 100, "last_name": "GUO", "first_name": "Yunnian", "sdn_type": "Individual", "programs": ["ILLICIT-DRUGS-EO14059"], "prohibition_type": "blocking", "matched_via": [{ "number": "8615815351839" }] },
{ "uid": "41376", "score": 100, "last_name": "YOULI TECHNOLOGY DEVELOPMENT CO., LTD.", "sdn_type": "Entity", "programs": ["ILLICIT-DRUGS-EO14059"], "prohibition_type": "blocking", "matched_via": [{ "number": "8615815351839" }] }
]
Captured from production on 2026-10-23. One phone number, four designated parties: the company and the three individuals OFAC designated with it on the same day, under the same program. That is the network OFAC's release calls "efforts by SDNs to obfuscate their involvement", visible from one field on one document.
Screen the email address Pegasus was writing to
On September 12, 2023, Pegasus instructed Youli—via communication with an email address identified as associated with Youli on the SDN List—to arrange with a Chinese shipping agent for the machine to be shipped to the United States.
Enforcement Release, page 2.
What failed
The email address was not on a document that arrived late. It was the address Pegasus itself used to give instructions, two weeks before it screened anything.
Noble's control
Email addresses OFAC publishes are identifiers like any other. Screening one takes the same request. Nothing about the match depends on the counterparty's current name.
Run it
curl -s -X POST https://api.noblesight.io/v1/screen -H "X-API-Key: $KEY" -H "Content-Type: application/json" -d '{"ids":[{"number":"yk@yolimachine.com"}],"lists":["ofac"]}'
The fields: matches[0].uid, matches[0].matched_via
"summary": { "verdict": "confirmed_match" },
"matches": [
{ "uid": "41376", "score": 100, "last_name": "YOULI TECHNOLOGY DEVELOPMENT CO., LTD.", "programs": ["ILLICIT-DRUGS-EO14059"], "prohibition_type": "blocking",
"matched_via": [{ "number": "yk@yolimachine.com" }],
"ids": [
{ "id_type": "Unified Social Credit Code (USCC)", "number": "91441300086828609C" },
{ "id_type": "Website", "number": "www.yolimachine.com" },
{ "id_type": "Email Address", "number": "yk@yolimachine.com" },
{ "id_type": "Phone Number", "number": "8615815351839" }
] }
]
Captured from production on 2026-10-23. The response returns every identifier OFAC published on the entry, so the analyst sees the whole fingerprint: registration number, website, email, phone. Any one of them on a document is enough.
Screen the document, not the name
A Pegasus employee failed to screen these identifiers in contravention of the company’s policy which called for screening “parties’ name, address, email, phone, and other information” against the SDN List. Screening the other identifiers, including through a basic internet search, would have yielded a positive match for Youli.
Enforcement Release, page 2. Aggravating factor 1: Pegasus showed "a reckless disregard for U.S. sanctions requirements by failing to properly screen information in its possession regarding Youli" (page 3).
What failed
The policy was right and the practice was a name lookup. A name lookup is one field of a shipping document. The release puts it plainly: "Sanctions screening against names on the SDN List, while critically important, is a baseline tool."
Noble's control
One request carries the name and every identifier on the document. The name is scored, each identifier is matched, and the response says which inputs hit which records. The alert is raised in the same call, and the screening record stores the whole request, so the audit trail shows the document was screened, not just the name.
Run it
curl -s -X POST https://api.noblesight.io/v1/screen -H "X-API-Key: $KEY" -H "Content-Type: application/json" -d '{"name":"Huizhou Youli Fushi Co., Ltd","ids":[{"number":"8615815351839"},{"number":"yk@yolimachine.com"}],"lists":["ofac"]}'
The fields: alert_id, summary.verdict, matches[].matched_via
"alert_id": 43304,
"summary": {
"verdict": "confirmed_match",
"top_match": { "uid": "41301", "name": "GUO, Chunyan", "score": 100, "source": "OFAC SDN" }
},
"matches": [
{ "uid": "41301", "score": 100, "matched_via": [{ "number": "8615815351839" }] },
{ "uid": "41356", "score": 100, "matched_via": [{ "number": "8615815351839" }] },
{ "uid": "41357", "score": 100, "matched_via": [{ "number": "8615815351839" }] },
{ "uid": "41376", "score": 100, "matched_via": [{ "number": "8615815351839" }, { "number": "yk@yolimachine.com" }] },
...
]
Captured from production on 2026-10-23. The same name that scored 36 alone is now part of a confirmed match with an alert, because the request carried what the document carried. Screen at the start of the transaction, when the email arrives, and the question never reaches Customs.
Pegasus screened at departure. Screen at first contact, then keep screening.
OFAC notes that Pegasus's procedure "made no mention of when to check the SDN List", and that it "waited until just before the machine was to depart China, by which point Pegasus had already engaged in prohibited conduct."
A name screened through POST /v1/screen is enrolled in portfolio monitoring on paid tiers, and re-screened against every list change as it is imported, so a counterparty designated after onboarding raises an alert without anyone remembering to re-check. Youli was designated on May 30, 2023 and the first shipment Pegasus arranged for this purchaser predates that. A monitored counterparty would have alerted on the day of designation, with the new identifiers attached.
Run the four requests against your own key
Keys are invite-only while Noble is in beta. Ask for an invite code and you will have a key, and the four responses above, in a few minutes.