The US OFAC SDN list explained

Who keeps the list and on what legal basis

OFAC administers and enforces US economic and trade sanctions. They target countries, regimes, individuals and entities that threaten US national security, foreign policy or the economy ¹. Many programs rest on the International Emergency Economic Powers Act. It lets the President use its powers against an unusual and extraordinary threat that has its source in whole or substantial part outside the United States, once the President declares a national emergency ⁴.

When read on 24 October 2026, the OFAC program page listed 36 programs, from Afghanistan-Related Sanctions to Yemen-related Sanctions ³. They include country programs such as Iran and North Korea and thematic programs such as Counter Terrorism, Cyber-Related and Global Magnitsky ³. The Treasury 2021 Sanctions Review, dated October 2021, referred to 37 existing sanctions programs ⁶. The two counts come from different dates and should not be read as a change in a single series.

What an SDN listing does

OFAC says US persons in most cases cannot deal with persons on the SDN List ¹. Blocking creates a broad ban on transfers and other dealings. Title stays with the blocked person, but using ownership rights needs OFAC authorization ¹. Property covers financial assets and real, tangible and intangible assets ¹.

US persons must comply wherever they are. This covers US citizens and permanent residents, anyone in the United States, and US-incorporated entities with their foreign branches ¹. Some programs reach foreign subsidiaries of US persons. Non-US persons can violate sanctions by causing a US person to violate them ¹. Violations can bring civil and, in some cases, criminal penalties ¹. OFAC reported 14 penalties, settlements or findings of violation totalling US$265,746,819 in 2025 ⁷.

The 50 Percent Rule

OFAC says entities owned 50 percent or more by blocked persons are, as a rule, blocked even if they are not named on the SDN List ¹. OFAC adds together the stakes of all blocked persons, including persons blocked under different programs ⁸. Indirect ownership through other blocked entities counts ⁸. The rule covers ownership only. An entity controlled, but not majority owned, by blocked persons is not blocked automatically, but OFAC may designate it separately ⁸.

The non-SDN lists

OFAC publishes other lists that carry restrictions short of full blocking. Their data sits in the Consolidated Sanctions List files ⁹.

Searching the list and asking for removal

Sanctions List Search covers the SDN List and the Consolidated (non-SDN) List ⁵. A score of 100 returns exact matches. Lower thresholds use fuzzy logic on the name field only ¹⁰. OFAC does not recommend a threshold and says the free tool should not be run continually by automated systems, which should use the list files instead ¹⁰. The tool shows current lists only, not removed names ¹⁰.

A blocked person may send arguments or evidence to OFAC.Reconsideration@treasury.gov. The person may argue there is an insufficient basis for the listing or that the circumstances no longer apply ². OFAC may ask for more information and then issues a written decision ². The Treasury 2021 review referred to over 12,000 OFAC designations and nearly 3,000 OFAC delistings, without stating the period ⁶.