OFAC Compliance Screening Lists - easyofac/docs GitHub Wiki

There is often a lack of clarity on which lists an OFAC screening includes. The Office of Foreign Asset Control (OFAC) maintains multiple financial sanctions programs and publishes this data on two primary lists:

  • Specially Designated Nationals and Blocked Persons List (SDN List)
  • Consolidated Sanctions List (Consolidated Non-SDN List)

Often people will refer to "SDN search" or the "SDN list" when speaking of OFAC compliance. In most cases, they are referring collectively to both the SDN and non-SDN list. The lack of distinction leads to confusion when the term "Non-SDN" comes up in search results. Within our own documentation, we try our best to refer to SDNs and non-SDNs distinctly and use words like "OFAC entities" to when we want to speak of OFAC list records more generally.

Specially Designated Nationals and Blocked Persons List (SDN List)

According to OFAC, SDNs include "individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries" and "individuals, groups, and entities...designated under programs that are not country-specific" are known as "SDNs". U.S. entities are generally prohibited from transacting with SDNs.

OFAC compiles information about SDNs, including names, addresses, aliases, tax IDs, passport numbers, dates of birth, nationalities, and any other pertinent data. It then publishes the data on what is known as the SDN List.

Consolidated Non-SDN List

The Consolidated Non-SDN list is effectively a "catch-all" that includes all other financial sanctions lists and executive orders not already covered by the SDN List:

  • Foreign Sanctions Evaders (FSE) List
  • Sectoral Sanctions Identifications (SSI) List
  • Palestinian Legislative Council (NS-PLC) list
  • The List of Foreign Financial Institutions Subject to Part 561 (the Part 561 List)
  • Non-SDN Iranian Sanctions Act (NS-ISA) List
  • List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List)​
  • Various Executive Orders as issued from time to time by the President

OFAC condenses all the non-SDN data to the Consolidated List and publishes the information in the same format as the SDN list. The result can be confusing as the Consolidated List contains data fields like "sdnEntry" and "sdnType", even though the data represents non-SDN entities. But because the data format is the same across both lists, searching becomes much more straightforward. Just keep in mind that if you see a data field mentioning "SDN" within the Consolidated List data set, it does not mean that entity is a "Specially Designated National."

Updates to Lists

From time to time, the government enacts new financial sanctions, perhaps through legislation, administrative order, or executive order. OFAC then adds these new entities to their lists, either to the Consolidated Non-SDN List or directly to the SDN List. OFAC may also add, move, or remove entities from lists to better organize them. For this reason, it is necessary to screen against both lists.

OFAC updates the lists as needed, and there is no set schedule as to when these updates are published. Executive orders, administrative orders, new legislation, and even routine maintenance to the lists may occur at any time. Screening against the most recent data is of utmost importance, so one must obtain a fresh copy of the sanction lists before any screening activity occurs.

Sanctions Programs

There are currently over 30 OFAC Sanctions Programs, covering just as many countries. To these programs, OFAC has assigned 70 different program tags. (A complete list is available here: https://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/program_tags.aspx.) Sanctions programs address specific countries or regions, and often particular industries or activities. Many have exemptions such as humanitarian aid or explicitly pre-approved transactions.

Because each program carries with it unique sanction requirements, it is necessary to note the program when examining a potential match. The sanction program may outline specific exceptions to sanctions, and the nature of your transaction may fall within this exception. For example, sanctions that apply to customers of a military manufacturing contractor may not affect customers of a homeowner's insurance company. Check with your legal counsel to know which programs apply to your organization.