Authority and purpose
OFAC is an office of the US Department of the Treasury. It administers and enforces economic and trade sanctions based on US foreign-policy and national-security goals. Sanctions are organized through programmes that can be country-related, thematic, activity-based or directed at particular threats.
What the SDN List contains
The SDN List names designated individuals, entities and groups, and can also identify blocked vessels and aircraft. SDN property and interests in property are generally blocked when they come within US jurisdiction, and US persons are generally prohibited from dealing with SDNs unless an authorization or exception applies. The exact effect depends on the governing authority and programme.
An SDN record can contain names and aliases, type, address, nationality, citizenship, dates and places of birth, identification documents, vessel or aircraft information, programme tags, remarks and a unique OFAC identifier. A programme tag helps lead the reader to the sanctions authority and programme material relevant to that designation.
Important OFAC peculiarities
- OFAC publishes the SDN List and separate consolidated non-SDN lists. Sanctions Sleuth currently screens the SDN dataset, not every non-SDN list.
- Some blocked property or entities may be affected under OFAC ownership rules even when their names do not appear on the SDN List.
- Aliases can be strong, weak, historical, transliterated or otherwise incomplete; they need to be assessed with the rest of the record.
- Programme tags and remarks are important context and should be checked against current OFAC programme pages and regulations.
Removal and mistaken identity
A listed person or authorized representative may petition OFAC for administrative reconsideration, commonly called a delisting petition. OFAC describes this as an administrative process rather than an automatic result. Someone who is not the listed person but is repeatedly mistaken for an SDN because of a similar name is directed by OFAC to its Compliance Hotline rather than the delisting process.
Official verification
- Use OFAC's Sanctions List Search or current downloadable SDN data.
- Confirm the OFAC unique identifier, programme tags and record type.
- Compare all names, addresses, birth details and identification documents available.
- Read the current programme page, regulations and recent OFAC actions associated with the designation.
- OFAC Sanctions List Service and search
- OFAC Specially Designated Nationals List
- OFAC sanctions programmes and country information
- OFAC removal and reconsideration guidance
A search of the SDN List alone does not cover all OFAC restrictions. Consult OFAC's non-SDN lists, ownership guidance and relevant programme rules where they may apply.