The OFAC SDN List: How Specially Designated Nationals Are Listed, Screened and Blocked

How OFAC designates an SDN

OFAC designates individuals and entities based on specified criteria, such as their connection to a targeted country, activity or regime, under a handful of statutory authorities. The main ones are the International Emergency Economic Powers Act (IEEPA), the Trading With the Enemy Act (TWEA), the Antiterrorism and Effective Death Penalty Act (AEDPA) and the Foreign Narcotics Kingpin Designation Act (Kingpin Act). Most modern designations run through IEEPA and a matching executive order.

Every entry carries one or more program tags showing which sanctions program it falls under, such as [SDGT] for global terrorism, [SDNTK] for the narcotics kingpin program or [IRAN] for the Iran program. A single entry can carry more than one tag. The tag tells you why the person was listed and which rules apply.

How to read an SDN entry

An SDN entry is built to be matched against. Beyond the primary name it carries a set of identifiers and one or more program tags. OFAC also flags some aliases as weak, meaning they are broad or generic aliases most likely to generate a false match. For the full make-up of an entry, see The OFAC Sanctions Lists.

What matters in practice is how you use those details. A screening system that compares only the primary name may trigger too many false-positive alerts. One that considers secondary identifiers can help filter out unnecessary alerts before a human ever sees them. When you review a hit, read past the name to the identifiers that confirm or rule it out.

Blocking, rejecting and reporting a match

A screening match is where the work starts. What you must do next depends on whether a blocked person has an interest in the property or funds involved.

Blocking applies when a blocked person has an interest in the property or funds involved. You freeze it. The funds go into a blocked interest-bearing account and no one may debit them without OFAC authorization. You do not return the money and you do not complete the payment.

Rejecting applies when a transaction is prohibited but no blocked person has an interest in the property or funds involved. You freeze nothing. You decline the transaction and send it back. Telling the two apart is a judgment about whose property is involved, so build it into your procedures rather than leaving it to the moment.

Both carry reporting duties. You have ten business days to report blocked property to OFAC, counted from the day you block it. A rejected transaction carries the same ten-business-day deadline. Separately, you file an annual report by September 30 that lists all blocked property you still held as of June 30. A late or missing report is its own violation, separate from the underlying transaction, even where the block was correct.

True matches and false positives

Most alerts are not real. Common names, transliterations and partial matches all trip a filter without meaning your customer is on the list. Clearing them is routine work. Doing it well is what keeps a team from either waving through a real SDN or freezing an innocent client.

Work the identifiers. Compare date of birth, place of birth, nationality and any ID numbers against your own records. A name that matches but a date of birth that does not match could indicate a false positive. When the identifiers line up or you cannot rule the match out, treat it as a potential true match and escalate before you act.

Ownership adds a second layer. Under OFAC's 50 Percent Rule, a company owned 50 percent or more, directly or indirectly, by one or more blocked persons is itself blocked, even if its own name never appears on any list. Matching names alone will not surface it, which is why ownership-structure checks sit alongside list screening. For the 50 Percent Rule and OFAC exposure in full, see OFAC Sanctions: An Overview.

How to screen against the SDN List

For a single name, OFAC runs a free Sanctions List Search tool that covers the SDN and Consolidated lists together, with fuzzy name matching so a near-miss spelling still surfaces. It is fine for a one-off check. It is not a compliance program.

What sets the SDN List apart is how often it moves. OFAC updates it on no fixed schedule, so a name that was clear last week can be listed today. That makes ongoing, automated screening and regular re-screening an important part of an effective, risk-based compliance approach. With dilisense you can search OFAC's SDN and consolidated lists, alongside EU, UN, UK and other sources, through a single API. The data updates hourly and every match is traceable to its origin. For how screening works in practice, see What is Sanctions Screening?.

Getting off the list

Designation is not always permanent. A listed person can seek delisting by petitioning OFAC for reconsideration. They write to OFAC with evidence that the basis for the sanction is wrong or no longer applies. They can propose steps to address OFAC's concerns, such as restructuring a company or resigning from positions in a blocked entity. A majority owner of blocked property may also propose selling it and placing the proceeds in a blocked interest-bearing account. OFAC can ask for more information and may grant a meeting, though it does not have to. It then issues a written decision. Removals happen, but on OFAC's terms and its timeline.