SanctionsLookupOFAC Consolidated Sanctions List: Non-SDN List Explained
The OFAC Consolidated Sanctions List is a critical but often overlooked list that any business processing USD transactions must comply with. It contains six non-SDN lists, and a match on any one of them is an enforceable violation carrying penalties of up to $377,700 per violation.
This article covers what the Consolidated Sanctions List is, which lists it contains, and what to do when you get a match.
- What is the OFAC Consolidated Sanctions List?
- Which lists are in the OFAC Consolidated List?
- How to screen against the OFAC Consolidated Sanctions List
- How to handle a Consolidated Sanctions List match
What is the OFAC Consolidated Sanctions List?
The OFAC Consolidated Sanctions List (CSL), also known as the non-SDN list, is a single published file containing all six of OFAC's non-SDN sanctions lists. It is maintained separately from OFAC's primary sanctions list and must be screened independently.
Unlike the SDN list, the Consolidated Sanctions List does not impose full blocking sanctions. Restrictions vary by list and by individual entry, ranging from specific financing prohibitions to correspondent account restrictions to investment bans.
The consolidated file currently contains approximately 1,920 entries across all six lists.
Which lists are in the OFAC Consolidated List?
The Consolidated Sanctions List contains six non-SDN lists, each targeting a different category of risk with different restrictions. None of them require full asset blocking, but all carry enforceable legal obligations.
| List | Full Name | Who it Targets | Restriction |
|---|---|---|---|
| FSE | Foreign Sanctions Evaders List | Individuals and entities that violated or evaded US sanctions | All transactions prohibited |
| SSI | Sectoral Sanctions Identifications List | Russian energy, defense, and financial sector entities | Specific debt and equity financing prohibited per Directives 1-4 |
| NS-MBS | Non-SDN Menu-Based Sanctions List | Parties subject to CAATSA and related statutory sanctions | Varies per entry, specified on a record-by-record basis |
| NS-PLC | Non-SDN Palestinian Legislative Council List | Hamas-affiliated Palestinian Legislative Council members | Transactions may be rejected |
| CAPTA | Correspondent Account or Payable-Through Account Sanctions | Foreign financial institutions subject to correspondent account sanctions | Correspondent and payable-through account restrictions or prohibition |
| NS-CMIC | Non-SDN Chinese Military-Industrial Complex Companies List | Chinese companies tied to the Chinese military | Purchase and sale of publicly traded securities prohibited |
1. FSE List — Foreign Sanctions Evaders
The FSE List targets individuals and entities that have violated US sanctions or helped others evade them. It is designed to cut off sanctions evaders from the US financial system without requiring full asset blocking.
- Purpose: Identify parties that have circumvented or violated US sanctions
- Who is listed: Individuals and entities of any nationality
- Restriction type: All transactions with FSE-listed parties prohibited
- Blocking required: No asset freeze required
- Current status: Empty as of December 2025, but new names may be added at any time
2. SSI List — Sectoral Sanctions Identifications
The SSI List targets specific sectors of the Russian economy rather than individuals. It restricts certain financial dealings with listed entities without imposing full blocking sanctions.
- Purpose: Limit financing to key Russian economic sectors
- Who is listed: Russian energy, defense, and financial sector entities
- Restriction type: Specific debt and equity financing prohibited under Directives 1 through 4
- Blocking required: No asset freeze required
- Current status: Active, regularly updated
3. NS-MBS List — Non-SDN Menu-Based Sanctions
The NS-MBS List targets parties subject to non-blocking sanctions under CAATSA and related authorities. Restrictions are not uniform. Each entry specifies which sanctions apply on a record-by-record basis.
- Purpose: Apply targeted non-blocking sanctions under CAATSA and related statutes
- Who is listed: Parties subject to statutory sanctions regardless of nationality
- Restriction type: Varies per entry, specified individually on each record
- Blocking required: No asset freeze required
- Current status: Active, check individual entries for applicable restrictions
4. NS-PLC List — Non-SDN Palestinian Legislative Council
The NS-PLC List targets Hamas-affiliated members of the Palestinian Legislative Council. It is one of the smallest and most static lists in the consolidated file.
- Purpose: Restrict dealings with Hamas-affiliated Palestinian Legislative Council members
- Who is listed: Hamas-affiliated PLC members elected on a terrorist organization party slate
- Restriction type: Transactions may be rejected rather than blocked
- Blocking required: No asset freeze required
- Current status: Small and rarely updated
5. CAPTA List — Correspondent Account or Payable-Through Account Sanctions
The CAPTA List targets foreign financial institutions subject to correspondent or payable-through account restrictions. It is primarily relevant for banks with international correspondent banking relationships.
- Purpose: Restrict or prohibit US banks from maintaining correspondent accounts for listed foreign financial institutions
- Who is listed: Foreign financial institutions meeting criteria under applicable sanctions authorities
- Restriction type: Outright prohibition or strict conditions on correspondent and payable-through accounts
- Blocking required: No asset freeze required
- Current status: Active, currently contains one listed institution
6. NS-CMIC List — Non-SDN Chinese Military-Industrial Complex Companies
The NS-CMIC List targets Chinese companies tied to the Chinese military under Executive Order 13959. It restricts investment activity rather than commercial transactions.
- Purpose: Prevent US investment in Chinese companies supporting the Chinese military
- Who is listed: Chinese companies identified as Chinese military-industrial complex companies
- Restriction type: Purchase and sale of publicly traded securities of listed companies prohibited
- Blocking required: No asset freeze required
- Current status: Active, primarily relevant for investment firms and asset managers
How to screen against the OFAC Consolidated Sanctions List
Screening against the Consolidated Sanctions List follows the same process as any OFAC sanctions screening.
One critical point: the Consolidated Sanctions List alone is not enough. The SDN list must be screened alongside it, as a party can be on one without appearing on the other.
For a full breakdown and how to automate it, see our OFAC screening guide. To screen both lists in one API call, see SanctionsLookup.
How to handle a Consolidated Sanctions List match
A Consolidated Sanctions List match does not automatically require blocking. The required action depends entirely on which sub-list the match came from.
- FSE: Transaction prohibited, no blocking required
- SSI: Check which Directive applies and restrict specific financing types accordingly
- NS-MBS: Check the individual entry for the specific sanctions that apply
- NS-PLC: Transaction may be rejected and returned, not blocked
- CAPTA: Check whether the correspondent account is prohibited or subject to conditions
- NS-CMIC: Check whether the transaction involves restricted securities
Regardless of which list the match comes from, document the match, the action taken, and retain records for a minimum of 10 years. If you are uncertain which action applies, contact OFAC directly via the OFAC Compliance Hotline.
For a full breakdown of penalties see our OFAC penalties guide.
FAQ
Is the Consolidated Sanctions List the same as the consolidated screening list?
No. The OFAC Consolidated Sanctions List is published by the US Treasury and contains six non-SDN OFAC sanctions lists. The Consolidated Screening List is a separate resource published by the US government's International Trade Administration and combines export control lists from the Commerce Department, State Department, and Treasury. They serve different purposes and must be screened against independently.
Can a party appear on both the SDN list and the Consolidated Sanctions List?
Yes. A party can be designated under multiple sanctions programs simultaneously and appear on both the SDN list and one or more non-SDN lists within the Consolidated Sanctions List. Screening against both lists is the only way to understand the full scope of restrictions that apply to a given party.
How often is the OFAC Consolidated Sanctions List updated?
The Consolidated Sanctions List has no fixed update schedule. OFAC updates individual sub-lists independently as new designations, removals, or modifications occur. The SDN list and Consolidated Sanctions List are updated on separate schedules, meaning an update to one does not indicate the other has also changed. Continuous monitoring of both lists is required.
Where can I download the Consolidated Sanctions List?
The Consolidated Sanctions List is available for free download in XML and CSV format through OFAC's Sanctions List Service. The file contains all six non-SDN lists in a single download. For automated screening without managing the raw files yourself, SanctionsLookup provides API access to both the SDN list and Consolidated Sanctions List with data synced every 15 minutes.
Does the 50 Percent Rule apply to the Consolidated Sanctions List?
No, not automatically. The 50 Percent Rule applies specifically to SDN-listed parties, meaning entities majority-owned by an SDN are treated as blocked even if they do not appear on the SDN list. The rule does not automatically extend to parties on the Consolidated Sanctions List. However, if a Consolidated Sanctions List party is also on the SDN list, the 50 Percent Rule applies through the SDN designation.
What is the difference between the Consolidated Sanctions List and the EU Consolidated Sanctions List?
They are entirely separate lists maintained by different authorities. The OFAC Consolidated Sanctions List is published by the US Treasury and covers non-SDN US sanctions. The EU Consolidated Sanctions List is published by the European Commission and covers sanctions imposed by the European Union. A party on one list may not appear on the other. Businesses operating across jurisdictions must screen against both independently.
Is the FSE list still active if it is currently empty?
Yes. The FSE list is an active OFAC sanctions list even though it currently contains no entries as of December 2025. OFAC can add new designations to the FSE list at any time. Screening systems should continue to check against it as part of any Consolidated Sanctions List screening process.