SDN List (SDN)
The SDN List is OFAC's list of Specially Designated Nationals and Blocked Persons — parties whose US-linked property is blocked and with whom US persons generally may not deal. It is the best-known part of US sanctions and nowhere near the whole of them.
Also called: Specially Designated Nationals list
OFAC maintains the SDN List under a range of sanctions programmes. An entry blocks the named person’s property and interests in property within US jurisdiction and, broadly, prohibits US persons from transacting with them. Screening against it is the baseline control in any sanctions screening programme, and a match is not a risk indicator to be weighed — it is a legal prohibition.
The mistake worth avoiding is treating the list as the perimeter. OFAC itself is explicit that sanctions reach parties that never appear on it. Under the 50 Percent Rule, an entity owned 50% or more, directly or indirectly, by one or more blocked persons is itself blocked whether or not it is separately named. Some programmes block whole categories of person, and comprehensive country programmes broadly prohibit most transactions involving a jurisdiction regardless of who the counterparty is. There are also non-SDN lists with different consequences: the Sectoral Sanctions Identifications List, for instance, names parties subject to restrictions other than blocking, and OFAC states plainly that the SSI List is not part of the SDN List.
So a clean SDN hit result answers one question. Ownership, jurisdiction, sector and the specific programme answer the rest, and each of them has produced enforcement against firms whose screening was working exactly as designed.
In practice
"Not on the SDN List" is not the same as "not sanctioned". The 50 Percent Rule alone means a counterparty can be fully blocked while appearing on no list at all, which is why ownership analysis — not name screening — is what actually catches it.
Example
A payment is made to a trading company that appears on no OFAC list. It is 60% owned by a designated entity. The company is blocked by operation of the 50 Percent Rule, the payment is a violation, and no screening tool configured only against the SDN List would have stopped it.
Commonly confused with
| Term | How it differs |
|---|---|
| OFAC | OFAC is the agency that administers US sanctions. The SDN List is one of the instruments it uses, alongside programme regulations, general licences and several other lists. |
| Sanctions Screening | Screening is the control. The SDN List is one of the datasets it is run against, and a screening programme limited to it is incomplete. |
| Consolidated Sanctions List | OFAC's compilation of its non-SDN lists, including the SSI List. Being on it carries restrictions, but not the blocking that SDN designation brings. |
See also
- OFACThe Office of Foreign Assets Control is the US Treasury office that administers and enforces US economic sanctions. It writes the programs, designates the people and companies caught by them, publishes the lists that firms screen against, and grants the licenses that permit otherwise prohibited dealings.
- Sanctions ScreeningSanctions screening is the checking of customers, counterparties and payment messages against sanctions lists and watchlists — at onboarding, repeatedly afterwards, and on payments while they are still in flight — and the holding or rejecting of anything that genuinely matches.
- Anti-Money LaunderingAnti-money laundering, usually shortened to AML, is the body of law, regulation and internal controls requiring financial firms to detect, prevent and report attempts to disguise the origin of criminal proceeds. It is an obligation placed on the firm, not a product the firm can buy.
- Ultimate Beneficial OwnerThe ultimate beneficial owner is the natural person who ultimately owns or controls a customer, identified by tracing ownership up through holding companies, trusts and nominees. Twenty-five percent is the common anchor in the United States, the United Kingdom and the European Union, but each states it differently and control is tested alongside it.
- Enhanced Due DiligenceEnhanced due diligence, or EDD, is the additional scrutiny applied where money laundering risk is higher. In the UK and the EU it is mandatory in prescribed cases — politically exposed persons, high-risk countries, correspondent banking — as well as wherever a firm’s own risk assessment says the baseline is not enough.