SDN list
SDN listAlso called specially Designated Nationals and Blocked Persons List, OFAC SDN list
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.
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.
The rules
Gives the President power to block property of designated foreign persons, the legal basis for most SDN designations.
US persons and transactions within US jurisdictionTreats entities owned 50% or more, directly or indirectly, by one or more blocked persons as blocked.
US persons dealing with entities owned by SDNsExtends the period for keeping records of sanctions-related transactions and blocked property from five to 10 years.
Anyone engaging in transactions subject to OFAC regulationsCommon 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.
