SDN List – OFAC Specially Designated Nationals and Blocked Persons

The Specially Designated Nationals and Blocked Persons List (SDN List) is a list maintained by the US Office of Foreign Assets Control (OFAC) of persons, organisations, and vessels with whom US persons are prohibited from doing business and whose assets located in the United States are frozen. The SDN List is the most effective instrument of American sanctions policy and has global compliance relevance.

• Scope: Over 18,000 entries (persons, companies, vessels, aircraft).
• 50% Rule: Entities owned 50%+ by SDN persons must also be blocked.
• Immediate effect: Listing automatically triggers asset freeze and transaction prohibition.
• Regular updates: OFAC updates the list continuously (several times per week).

The SDN List emerged as a consolidated instrument from various earlier OFAC lists during the 1990s. Initially dominated by entries from the narcotics sanctions programme (SDNTK) and Cuba/Iran programmes. After 9/11 2001 and the issuance of Executive Order 13224, the list was massively expanded to include terrorism entries (SDGT). The financial crisis and geopolitical developments (Russia 2014, 2022; North Korea; Venezuela) led to exponential growth of the list. Today the SDN List contains over 18,000 entries from over 40 sanctions programmes. High-profile enforcement cases (BNP Paribas 2014, Société Générale 2018) have made SDN compliance a global standard that non-US banks must also follow.

The SDN List affects:

• All US persons (citizens, residents, US companies) directly and with full compliance obligation
• Non-US banks processing dollar transactions (secondary sanctions risk)
• Multinational companies with US nexus

Entry types: persons (natural, legal), vessels, aircraft; organised by sanctions programme (SDT, SDGT, SDNTK, IFSR, etc.).

• US persons may not conduct any transactions with SDN entries; violation is a criminal offence.
• All assets of SDN entries located in the United States must be frozen.
• 50% Rule: entities in which SDN persons hold 50%+ are automatically blocked – even if not explicitly listed.
• Real-time screening against the daily updated SDN List is best practice.
• OFAC licence required for any exception (humanitarian licence, specific licence).
• Reporting obligation for blocking events to OFAC (Blocking Notice).
• Listed persons may file a Petition for Removal with OFAC to request delisting.

5 corrections:
- EO 13224 was signed September 23, 2001, not September 24
- 50% Rule guidance: date 2006-06-13 is incorrect
- Russia sanctions date 2022-02-01 is incorrect
- SDN entry count severely outdated: 18,664 not 12,000
- Number of sanctions programmes outdated: 72 not 35
2 updates:
- last_amended placeholder date 2024-01-01 is outdated
- Official URL redirects to new OFAC Sanctions List Site
1 clarification.
1 note.