The SDN List (Specially Designated Nationals and Blocked Persons List) is the U.S. Department of the Treasury’s main register of individual sanctions. It is administered by OFAC (Office of Foreign Assets Control) and contains the names of individuals, companies, organizations and vessels whose assets are blocked by the U.S. government.
Dealing with an entity on this list —or with a company owned 50% or more by one or more listed entities— can lead to civil and criminal penalties and exclusion from the U.S. financial system.
That liability is not limited to U.S. companies: any organization that uses the U.S. dollar, U.S.-origin products or technology obtained from the United States for the transaction, or intermediaries within U.S. jurisdiction may be affected.
This guide explains what the SDN List contains, how to search it, how the 50 Percent Rule works and what a non-U.S. company should do to manage this risk.
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What the SDN List Is and Who Administers It
The SDN List (Specially Designated Nationals and Blocked Persons List) is the public register maintained by OFAC of individuals, companies, organizations and vessels whose assets have been blocked by the U.S. government. OFAC is part of the Department of the Treasury and acts in pursuit of national security and foreign policy objectives.
Persons and entities on the SDN List are designated because, according to OFAC, they pose a threat in one of these categories, among others: terrorism, narcotics trafficking, proliferation of weapons of mass destruction, cybercrime, human rights abuses or acting on behalf of sanctioned governments.
The legal basis for SDN designations comes from several federal statutes. The most relevant are the International Emergency Economic Powers Act (IEEPA), the Trading With the Enemy Act (TWEA), the Foreign Narcotics Kingpin Designation Act and the Antiterrorism and Effective Death Penalty Act. Each sanctions program operates under one or more of these laws.
The list has no fixed update schedule. OFAC adds or removes names whenever it deems necessary and publishes each change on its recent actions page (ofac.treasury.gov/recent-actions). The list is distributed in multiple formats —PDF, XML, CSV and delimited files— to make it easier to integrate into automated compliance systems.
To understand the general framework of OFAC sanctions and how its different programs fit together, see our complete guide.
Which Sanctioned Party Lists Does OFAC Maintain Besides the SDN List?
OFAC administers several sanctioned party lists with different levels of restriction. The SDN List is the most severe —it entails full asset blocking and a prohibition on any transaction— but it is not the only one. Knowing the differences is essential to configure a screening system correctly.
| List | What it includes | Main restriction | Asset blocking? |
|---|---|---|---|
| SDN List | Persons, companies, organizations and vessels designated under multiple sanctions programs | Total prohibition on transactions for U.S. persons; blocking of all assets under U.S. jurisdiction | Yes |
| SSI List (Sectoral Sanctions Identifications) | Persons and entities in specific sectors of the Russian economy (energy, finance, defense) | Selective prohibitions: restrictions on debt, equity and specific transactions, not full blocking | No (unless they are also on the SDN List) |
| NS-MBS List (Non-SDN Menu-Based Sanctions) | Entities subject to modular prohibitions under specific programs | Variable combination of restrictions depending on the applicable directive | Depends on the directive |
| CAPTA List | Foreign financial institutions subject to correspondent banking restrictions | Prohibition on opening or maintaining correspondent or payable-through accounts in the United States | No |
| FSE List (Foreign Sanctions Evaders) | Foreign persons and entities that have violated or facilitated the evasion of sanctions against Iran | Prohibition on transactions for U.S. persons. Note: since December 2025 this list has been empty, but new entries can be added at any time | No |
| Consolidated Sanctions List (non-SDN) | A unified compilation of all non-SDN lists in a single downloadable file | Varies according to the source list of each entry | Varies |
OFAC’s lists have different objectives and legal requirements from the lists of BIS (Bureau of Industry and Security), such as the Entity List. That is why there is no combined OFAC-BIS list. However, the same person or company may appear on both. For companies that handle technology or components subject to EAR and ITAR export controls, screening must cover both lists.
How to Search the SDN List Step by Step
OFAC offers a free online search tool —Sanctions List Search— that lets you check whether a person or entity appears on the SDN List or on any other OFAC sanctions list. It is available at sanctionssearch.ofac.treas.gov and requires no registration.
OFAC’s Sanctions List Search
Sanctions List Search is OFAC’s official screening tool. It allows searches by name, alias, country, entity type and sanctions program. The tool uses fuzzy logic in the name field: it does not require an exact match but returns results with similarity scores to capture spelling variations and aliases.
Each result shows the name of the designated entity, the sanctions program under which it was listed, its nationality, date and place of birth (for individuals), identification numbers and known aliases.
What to Do If There Is a Match
A positive result in Sanctions List Search does not automatically mean the counterparty is sanctioned. There are three possible scenarios:
- Exact match (true hit): the name, identifiers and location match. If U.S. persons or another U.S. nexus is involved, the transaction must be stopped immediately. If assets are under your control, they must be blocked and reported to OFAC within 10 business days.
- Partial match: the name is similar but the additional details do not fully match. OFAC recommends investigating further —checking identity documents, addresses, passport number— and, if doubts remain, contacting the OFAC hotline (1-800-540-6322) for verification.
- False positive (false hit): the name partially matches, but the geographic location, identifiers and context bear no relation to the list entry. The check carried out is documented and filed as part of the compliance record.
What is never acceptable is ignoring a match or proceeding with the transaction without verification. That behavior constitutes, at a minimum, reckless conduct under OFAC’s enforcement guidelines.
Other Ways to Access the SDN List
In addition to the online search tool, OFAC offers the full SDN List for direct download through its Sanctions List Service (ofac.treasury.gov/sanctions-list-service). Available formats include XML, CSV and delimited files, designed to be integrated into automated screening systems. An email notification service is also available that sends an alert whenever the list is updated.
For organizations with a high volume of counterparties, manual screening is not enough. Automated systems allow the entire base of customers, suppliers and intermediaries to be screened continuously against the updated lists.
The 50 Percent Rule: Why the SDN List Does Not Show All Blocked Entities
OFAC’s 50 Percent Rule provides that any entity owned 50% or more —directly or indirectly, individually or in the aggregate— by one or more blocked persons is automatically considered blocked, even if it does not appear on the SDN List. This rule is one of the most underestimated sources of risk in sanctions compliance.
The rule works like this: if Person A (on the SDN List) owns 30% of Company X, and Person B (also on the SDN List) owns 25% of the same company, their aggregate ownership reaches 55%. Company X is blocked, even though its name does not appear on any OFAC list. Any transaction with it is a potential violation.
The rule also operates indirectly. If an SDN-designated person owns 60% of Company A, and Company A owns 70% of Company B, then Company B is also considered blocked through that ownership chain. Identifying these connections requires a beneficial ownership analysis that goes well beyond a simple list search.
OFAC does not publish a separate list of entities blocked under the 50 Percent Rule. Responsibility for identifying them lies entirely with the party carrying out the transaction. This makes investigating the ownership structure a critical element of counterparty due diligence.
On March 31, 2026, OFAC published a new advisory on “Sham Transactions and Sanctions Evasion” (ofac.treasury.gov/recent actions/20260331_33) that reinforces a fundamental principle: the 50 Percent Rule is a minimum due diligence threshold, not a ceiling.
OFAC expects organizations to look beyond legal formalities to assess the economic and practical realities of each transaction. An ownership structure designed to fall just below 50% may constitute sanctions evasion if OFAC determines that the designated person retains effective control.
Although the obligation to block assets does not apply to non-U.S. entities dealing with parties blocked under the 50 Percent Rule when there is no U.S. nexus, such transactions may nonetheless trigger OFAC secondary sanctions, with the resulting risk of exclusion from U.S. markets.
Non-U.S. entities also need to screen shareholding structures so they can give financial institutions and other counterparties the representations and warranties that no dealings with sanctioned parties exist, which these counterparties normally require —even from non-U.S. entities— in most financial or commercial transactions.
What Are the Consequences of Dealing with an SDN-Listed Entity?
Dealing with a person or entity on the SDN List —or blocked under the 50 Percent Rule— can lead to civil and criminal penalties and operational restrictions. These consequences reach both U.S. companies and non-U.S. companies with a jurisdictional nexus to the United States.
Consequences for U.S. Companies
OFAC civil penalties operate under strict liability. This means a company can be penalized even if it did not know it was dealing with a blocked entity. Neither intent nor negligence is required: it is enough that the transaction took place.
Civil penalties under IEEPA can reach the greater of these two amounts: USD 377,700 per violation (inflation-adjusted figure in effect in 2026) or twice the value of the underlying transaction. Willful violations can result in penalties of up to 20 years in prison and fines of up to USD 1,000,000 per violation.
In addition, any property of the SDN entity located in the United States or under the control of a U.S. person must be blocked immediately and reported to OFAC within 10 business days.
Consequences for Non-U.S. Companies
A non-U.S. company can be penalized by OFAC if its dealings with an SDN entity involve the U.S. financial system —for example, a dollar payment that passes through a U.S. correspondent bank— or if it causes a U.S. person to violate sanctions.
A documented case illustrates this clearly: Toll Holdings Limited, an Australia-based logistics company, agreed to pay USD 6,131,855 to settle its civil liability for 2,958 apparent violations of multiple OFAC sanctions programs. The company had originated or received payments through the U.S. financial system in connection with shipments involving North Korea, Iran and Syria and blocked parties in those countries. OFAC determined that Toll acted recklessly by failing to implement policies to prevent those transactions (Source: Tri-Seal Compliance Note, Departments of the Treasury, Commerce and Justice, March 6, 2024).
The exposure is not limited to fines. Exclusion from the U.S. financial system —the inability to process dollar payments or maintain correspondent relationships with U.S. banks— can have a more serious operational impact than the financial penalty itself.
Non-U.S. companies are exposed to this risk when their transactions involve entities on the SDN List or blocked under the 50 Percent Rule.
For a detailed analysis of the types of penalties and their consequences, see our article on the consequences of violating OFAC sanctions.
How Can a Non-U.S. Company Be Affected by the SDN List?
A non-U.S. company can be affected by the SDN List if it carries out dollar transactions, uses U.S.-origin technology, or has employees or partners with a jurisdictional nexus to the United States. These scenarios are more common than many organizations assume.
Scenario 1 — Blocked dollar payment. A Latin American company pays an Asian supplier in USD. The supplier turns out to be an SDN-listed entity. The payment passes through a correspondent bank in New York, which blocks it on detecting the match. The Latin American company loses the funds for as long as the blocking lasts and is exposed to an OFAC investigation for having caused a U.S. financial institution to process a prohibited transaction.
Scenario 2 — Counterparty blocked under the 50 Percent Rule. A European company signs a contract with a distributor that does not appear on any sanctions list. However, 55% of the distributor is owned by two SDN-designated persons. The distributor is automatically blocked. If the payment is routed through the U.S. financial system or involves U.S.-origin technology obtained in the United States for this transaction, the European company has carried out a prohibited transaction without knowing it.
Scenario 3 — Reexport of U.S.-origin components. A company manufactures equipment that incorporates U.S.-origin components and sells it to an end customer that appears on the SDN List. The transaction creates double exposure: before OFAC for dealing with a sanctioned entity, and before BIS for reexporting items subject to the EAR without a license. To understand how the two jurisdictions interact, see our guide on the extraterritorial reach of U.S. sanctions.
In all three scenarios, the common denominator is the same: the non-U.S. company does not need to have intended to violate sanctions. Mere contact with the U.S. financial system or with U.S. technology obtained from the United States for the transaction triggers OFAC jurisdiction.
Frequently Asked Questions About the SDN List
How often is the SDN List updated?
The SDN List has no fixed update schedule. OFAC adds or removes names whenever it deems necessary in light of its national security and foreign policy objectives. All changes are published on OFAC’s recent actions page (ofac.treasury.gov/recent-actions) and reflected cumulatively in the SDN List PDF file for the current year. Companies can subscribe to email alerts to receive automatic notifications whenever the list changes.
Is it possible to be removed from the SDN List?
Yes. OFAC accepts formal petitions for administrative reconsideration. The process requires showing that the designation was mistaken or that the circumstances that prompted it have changed substantially. It is a complex procedure with no guaranteed decision timeframe, and OFAC is not required to remove a person or entity from the list. Petitions usually require specialist support in U.S. sanctions.
Does the SDN List only affect U.S. citizens and companies?
No. Although the direct SDN prohibitions apply to U.S. persons (citizens, permanent residents, persons within the United States and entities organized under U.S. law), the real reach is global. Through secondary sanctions, the 50 Percent Rule and the jurisdictional nexus created by any dollar payment or the use of U.S.-origin technology, the SDN List affects companies in any country that takes part in international trade.
What is the difference between the OFAC SDN List and the BIS Entity List?
The SDN List is an economic sanctions instrument administered by the Department of the Treasury (OFAC). The Entity List is an export control tool administered by the Department of Commerce (BIS). The SDN List blocks assets and prohibits any transaction. The Entity List imposes license requirements to export, reexport or transfer items subject to the EAR. Their regulatory objectives differ and there is no combined list. However, the same entity may appear on both, creating compliance obligations before two agencies at the same time. For more information on EAR and ITAR export control regulations, see our guide.
Free download: OFAC/EAR/ITAR Risk Checklist (in Spanish)
Do you know whether any of your counterparties appear on these lists? This checklist lets you assess in 15 minutes your company’s most critical points of exposure to U.S. sanctions and export controls.
