SanctionsLookupOFAC Sanctions List: Screening One List is Not Enough
The OFAC sanctions list is not a single list. OFAC maintains seven separate sanctions lists, each with different legal obligations and consequences for dealing with a sanctioned party. Screening against only one of them leaves you exposed to the rest. This article covers what each list is and how to screen against all of them.
- What is the OFAC sanctions list?
- What are OFAC sanctions programs?
- SDN list vs non-SDN list
- OFAC sanctioned countries
- How often is the OFAC sanctions list updated?
- How to screen the OFAC sanctions list
What is the OFAC sanctions list?
The OFAC sanctions list is a set of seven lists maintained by the Office of Foreign Assets Control, a division of the US Department of the Treasury. Each list has different legal obligations and consequences for non-compliance.
Their primary purpose is to identify parties subject to US sanctions restrictions, blocking them from accessing the US financial system and transacting with US persons.
The seven lists fall into two main categories:
- The SDN List is the primary blocking list with over 17,000 entries. Dealing with anyone on it requires blocking their assets and halting all transactions.
- The remaining six lists are published together as the Consolidated Sanctions List and impose targeted restrictions such as financing limits, transaction bans, and correspondent account prohibitions without requiring full blocking.
Screening against only one list is not enough. A party can be on the Consolidated Sanctions List without appearing on the SDN list, and dealing with them constitutes an apparent violation under the same strict liability standard.
What are OFAC sanctions programs?
A sanctions program is the legal basis for why someone ends up on the OFAC sanctions list, defining who can be targeted and what transactions are banned.
When the US government wants to restrict dealings with a country, a terrorist network, or a corrupt oligarch, it creates a sanctions program through an Executive Order or Act of Congress.
OFAC administers over 30 active sanctions programs, each authorized through legislation including IEEPA and TWEA. Each list entry is tagged with the program it falls under, telling you why they were designated and what rules apply.
Programs fall into two categories:
Country-based programs restrict entire jurisdictions:
- Iran, Cuba, North Korea, Syria: near-total transaction bans
- Russia, Belarus, Venezuela: targeted sectoral restrictions
Activity-based programs target specific threats regardless of geography:
- SDGT: global terrorism
- NPWMD: weapons proliferation
- SDNTK: narcotics trafficking
- CYBER: cybercrime and malicious cyber activity
The program determines what is prohibited, not just whether a name appears on a list. Under country-based programs like Iran or Cuba, entire categories of transactions are banned regardless of whether the counterparty is designated.
SDN list vs non-SDN list
The key difference between the SDN list and the Consolidated Sanctions List (non-SDN list) is the required action on a match.
- An SDN List match means full blocking. Assets are frozen, all transactions halted, and the action reported to OFAC within 10 business days.
- A Consolidated Sanctions List match triggers targeted restrictions that vary by list: financing limits, correspondent account prohibitions, or transaction bans with specific entities, but no automatic asset freeze.
| Feature | SDN List | Consolidated List (non-SDN) |
|---|---|---|
| Entry types | Individuals, companies, vessels, aircraft, crypto wallets | Individuals, entities, financial institutions |
| Sub-lists | Single list | FSE, SSI, NS-MBS, NS-PLC, CAPTA, NS-CMIC |
| Number of entries | 17,000+ | ~1,920 |
| Sanctions type | Full blocking | Targeted restrictions |
| Asset treatment | Assets frozen | No automatic blocking |
| Transaction prohibition | All prohibited | Varies |
| 50 Percent Rule | Applies | Not automatically |
| Reporting obligation | 10 business days | Varies |
| Legal authority | IEEPA, TWEA, UNPA | Varies |
| Update frequency | Irregular, frequent | Irregular |
| File formats | XML, CSV | XML, CSV |
Need to screen against both lists? SanctionsLookup checks the SDN list and Consolidated Sanctions List in one API call.
Both lists are mandatory to screen against, carry independent legal obligations, and operate under the same strict liability standard. Intent is irrelevant and violations are enforceable regardless of whether you knew the party was listed.
Important distinction: the 50 Percent Rule applies to SDN entries, meaning unlisted entities majority-owned by a sanctioned party are treated as blocked. Identifying these requires beneficial ownership data beyond standard name screening. This does not automatically apply to non-SDN lists.
When you get a match, which list it came from determines what you do next.
OFAC sanctioned countries
OFAC does not publish an official list of sanctioned countries. Instead, it administers sanctions programs that restrict dealings with entire jurisdictions, specific sectors, or named individuals. Country-based sanctions can prohibit entire transaction categories regardless of whether a counterparty appears on any list.
There are two levels:
- Comprehensive sanctions — near-total transaction bans on Iran, Cuba, North Korea, Syria
- Targeted sanctions — specific sector, entity, or activity restrictions:
- Russia: energy, defense, financial sectors
- Venezuela: oil sector, government officials
- Belarus: targeted individuals and entities
To check if a country is sanctioned, look it up on OFAC's Sanctions Programs and Country Information page. For comprehensive sanctions countries, all transactions are prohibited without an OFAC license. For targeted sanctions countries, check whether the specific transaction type is restricted under that country's program.
How often is the OFAC sanctions list updated?
The OFAC sanctions list has no fixed update frequency. Updates occur whenever new designations, removals, or modifications happen, which can be any time. During active geopolitical events, updates can occur multiple times a week.
Periodic screening is not enough. A counterparty clean at onboarding can be designated the next day. Continuous monitoring against the latest list data is the most reliable way to reduce exposure between designations.
Always up to date: SanctionsLookup syncs OFAC list data every 15 minutes. If OFAC adds a new entry, your next screening call will catch it.
How to screen the OFAC sanctions list
Searching the OFAC sanctions list means checking against both the SDN list and the Consolidated Sanctions List. There are two ways to do it depending on your volume and use case:
- Manual: For ad hoc checks such as screening a single name, verifying a counterparty, or validating a one-off transaction. Our OFAC sanctions list search tool covers both lists with fuzzy matching for aliases and transliterations.
- Automated: Use an OFAC API for production screening at scale, including onboarding, transaction screening, and continuous monitoring. Every call checks against both lists in real time with no manual steps required.
Both tools use official OFAC sanctions list data synced every 15 minutes, so every search is checked against the most current designations.
FAQ
Does the OFAC sanctions list include crypto wallet addresses?
Yes, but only the SDN list. OFAC designates cryptocurrency wallet addresses the same way it designates individuals and companies, and they appear directly on the SDN list. Sending or receiving funds from a listed wallet address is a sanctions violation regardless of whether you knew the address was designated.
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, which means they can appear on both the SDN list and one or more non-SDN lists at the same time. Screening against both lists is the only way to catch all designations and understand the full scope of restrictions that apply.
How is OFAC different from EU or UK sanctions lists?
OFAC is a US authority. The EU maintains its own Consolidated Sanctions List enforced across all member states. The UK maintains a separate list administered by OFSI. A party not on the OFAC SDN list may still be sanctioned under EU or UK rules. Businesses operating across jurisdictions need to screen against all relevant lists, not just OFAC.
What is the difference between blocking and rejecting a transaction?
Blocking applies to transactions involving SDN-listed parties. The funds are frozen, held by the business, reported to OFAC within 10 business days, and reported annually until OFAC instructs otherwise. Rejecting applies to transactions that are prohibited but do not involve blocked property — the transaction is declined and funds returned to sender. Both carry separate reporting obligations.
Are the SDN list and Consolidated Sanctions List updated at the same time?
No. They are updated independently on separate schedules. An SDN update does not automatically trigger a consolidated list update and vice versa. This means screening systems need to monitor both lists separately for changes, not assume that one update covers both.
How do you know when OFAC updates its sanctions lists?
OFAC publishes all list updates on its recent actions page and offers email subscription alerts for list changes. In practice most businesses rely on their screening provider to monitor updates automatically. SanctionsLookup syncs OFAC list data every 15 minutes so changes are reflected in every API call without manual monitoring required.