Standards
OFAC Specially Designated Nationals and Blocked Persons List
A U.S. sanctions list of designated persons and entities published by OFAC.
- Kind
- Registries
- Steward
- U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
- Official source
- https://ofac.treasury.gov/sanctions-list-service
What it describes
OFAC publishes the Specially Designated Nationals and Blocked Persons List as part of its sanctions program administration. Entries can include names, aliases, identifiers, addresses, and program tags. The list is a maintained government source for screening and review. A candidate name match is only a lead: it must be assessed against available identifiers, context, and the current official entry.
The SDN List is not the complete universe of U.S. sanctions restrictions, and absence from it does not establish that a transaction is permitted. Entries can be added, amended, or removed. Retain the list version or retrieval timestamp, matched entry, match evidence, and applicable program context. Legal obligations depend on the rules in force and the facts of the transaction.
Useful for
- Screen names against official entries.
- Review aliases and identifiers.
- Audit which list version informed a decision.
Limits
- Name similarity is not confirmed identity.
- Absence does not establish permission.
- Other sanctions restrictions may apply.
How it is used in practice
Financial institutions, exporters, marketplaces and many other businesses screen customers, counterparties, vessels and payments against the SDN List. OFAC publishes the list on its Sanctions List Service in several downloadable formats and keeps a record of recent actions that notes additions, removals and amendments. Each entry has a name, may have aliases of varying quality, and may include addresses, dates and places of birth, identification numbers and the sanctions programs under which the designation was made. The agency's FAQs explain how to interpret the list, including the rule that entities owned in the aggregate fifty percent or more by blocked persons are themselves blocked even if they are not named.
Screening produces candidate matches, and a human or a documented rule resolves them. The record of how each candidate was resolved is as important as the list itself, because it is what a regulator or an auditor will ask to see.
A worked example
A fictional marketplace screens a new seller, Halden Trading Ltd, against the SDN List. The screening tool returns a candidate: an entry with a similar name, a different country and no matching identifiers.
The reviewer opens the official entry, compares the identifiers, addresses and dates with the seller's documents, and records the finding: the name is similar, but the identifying details do not match, and the entry's program and listing date are noted. The decision, the list version or retrieval time, the reviewer and the evidence are stored. Two weeks later OFAC adds a new entry for a different entity with a closer name. The earlier decision stays valid for the earlier list; a rescreening on the new version produces a new candidate and a new, separately recorded decision. Neither erases the other.
Evaluating a claim that rests on a screening result
A clear screening result is a statement about a name against a list version. It does not show that a counterparty is lawful to deal with, and it does not cover other lists, ownership structures that the name does not reveal, or jurisdictions with their own rules. The legal question is answered by applying the regulations to the facts, usually with counsel, not by the screening alone.
Look at the matching method. Transliteration, aliases and weak aliases mean that an exact match is not the right test, and that a fuzzy match produces false positives. The method's thresholds, the alias treatment and the lists searched belong in the record, with the version of each list, so that the screening can be explained and, if needed, reproduced.
Confusions to avoid
The SDN List is one of several OFAC lists, and the other lists carry different prohibitions. Appearing on a non-SDN list does not mean the same thing as being blocked, and the entry shows which list and program apply. It is also not the whole of U.S. sanctions or export controls, which include other agencies and instruments.
A match is not a finding of identity. A common name is not evidence, and a missing alias in the list does not show that two persons are different. The record should state the standard of evidence used to reach a decision and keep both the supporting and the contrary facts. OFAC's published framework for compliance commitments describes the elements of a compliance programme, including testing and auditing, and gives context for why decision records matter.
Questions a reviewer can ask
Which list version or retrieval time was screened? What matching method and thresholds were used, and how were aliases treated? Which identifiers were compared in resolving each candidate? Who made the decision, on what evidence, and is it recorded? Was ownership or control examined, or was that out of scope? Is the decision tied to the version it was made on, with rescreening dated separately?
Related terms
Found an error on this page? See corrections for what counts as one, how to report it and the dated log.
Enquiry
Which of your sources carry OFAC Specially Designated Nationals and Blocked Persons List?
Tell us which sources carry it, which key the same entity some other way and who may read which. We reply with whether and how a first record would use this registry.
Or write to [email protected] in your own words.