SDN list

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Glossary · Sanctions

SDN list

SDN listAlso called specially Designated Nationals and Blocked Persons List, OFAC SDN list

Definition

The SDN list is the Specially Designated Nationals and Blocked Persons List published by the US Treasury's Office of Foreign Assets Control. It names individuals, companies, vessels and aircraft whose property in US jurisdiction is blocked. US persons are generally barred from dealing with them, and firms worldwide screen against it.

01 INDIVIDUALS02 ENTITIES03 VESSELS04 AIRCRAFT
Fig. 1 · SDN list
IEEPA · OFAC 50% rule · 31 CFR 501.601
Key rulesIEEPA · OFAC 50% rule · 31 CFR 501.601
Applies toUS persons and transactions within US jurisdiction
RegionsUS · Global
01

How it works

Firms screen customers, counterparties and payments against the SDN list, usually with fuzzy matching on names, aliases, dates of birth and identifiers. A true match means the firm blocks the property or rejects the transaction and reports it to OFAC, usually within 10 business days. Entities owned 50% or more by SDNs are treated as blocked too.

The list matters beyond the US because dollar payments clear through US banks and OFAC applies strict liability civil penalties. Secondary sanctions can also reach non-US firms. OFAC updates the list often, sometimes several times a week, so screening tools must load each change quickly and rescreen existing customers.

Step 1Load updatesIngest each OFAC list change promptly
Step 2Screen namesMatch customers and payments using fuzzy logic
Step 3Check ownershipApply the 50% rule to owned entities
Step 4Block and reportFreeze property and report to OFAC
02

The rules

US · 28 December 1977IEEPAInternational Emergency Economic Powers Act

Gives the President power to block property of designated foreign persons, the legal basis for most SDN designations.

US persons and transactions within US jurisdiction
US · 13 August 2014OFAC 50% ruleOFAC revised guidance on entities owned by persons whose property is blocked

Treats entities owned 50% or more, directly or indirectly, by one or more blocked persons as blocked.

US persons dealing with entities owned by SDNs
US · 21 March 202531 CFR 501.601OFAC Reporting, Procedures and Penalties Regulations, recordkeeping requirements

Extends the period for keeping records of sanctions-related transactions and blocked property from five to 10 years.

Anyone engaging in transactions subject to OFAC regulations
03

Common questions

Who must comply with the SDN list?

US persons, including US citizens, residents, companies and anyone in the US, as well as foreign branches of US firms. Non-US firms screen against it because dollar payments clear through the US and secondary sanctions can apply.

What happens if a customer matches the SDN list?

After confirming a true match, a US firm blocks the property or rejects the transaction. It reports the action to OFAC, generally within 10 business days, and keeps records for 10 years.

Are companies owned by SDNs also sanctioned?

Yes. Under OFAC's 50% rule, an entity owned 50% or more, in total, by one or more blocked persons is itself blocked, even if it does not appear on the list.