OFAC removed 125 people and companies on 5 October. Its own page prints 181 rows, and 18 more aliases went with the updates

OFAC deleted 125 entries from the SDN List on 5 October and rewrote 22 others. Treasury's release calls it the third round of the modernization effort Treasury Secretary Scott Bessent announced in May. The release gives two numbers. OFAC's page gives more.

Treasury says the removals followed interagency review, and that the updates "added new identifiers and removed outdated ones". The release points to the recent-actions page as its complete list and does not say which reason applies to which entry. It also counts the 18 September removal of six entries under the Ethiopia programme as part of the same effort.

We counted the page ourselves, from the HTML. There are 181 deletion rows: 114 tagged [SDNT], 59 [IRAQ2], 4 [VENEZUELA] and 4 [BELARUS-EO14038]. Treasury says 125.

The gap is aliases. OFAC's page prints a subject once under each of its names, so one person or company can take several rows. Tariq Abu Shanab Est. for Trade & Commerce, an Iraq-programme establishment at Musherfeh, Zarka, Jordan, takes eight rows by itself. Hikmet Abdallah al-Bazzaz takes two, one per spelling of his name.

When we joined every alias row to the entry it repeats, 181 rows became exactly 125 subjects: 78 individuals and 47 entities. So Treasury's figure is the right one to quote, and 181 is the right one to expect in a data file. A total below 125 cannot be reproduced from the page.

The count does not stop there. The page lists 22 updates, matching Treasury. But in the cumulative change file, three of the update groups carry a paragraph beginning "resulting in the removal of the following". Those name 18 further alias rows that were deleted without appearing on the page as deletions: 13 under [SDNTK], 4 for the tanker NAVARZ and 1 for LA PEARL. They are not part of the 125, because the entries they belonged to stay listed. A row-by-row diff of your own file against the new SDN List should therefore find 199 rows gone: 181 plus 18.

Treasury's third reason, entries too thin to screen against, is an argument about false positives. We checked what the printed rows carry.

The thin entries are the Iraq-programme ones. Of 34 individuals, 30 have neither a birth date nor a document number, and some are located only as "Iraq". Wallid Issa Ahmad is a name, the word Iraq, and nothing else. Entries like that are what false positives are made of, and a screening file is better without them.

The 40 narcotics-programme individuals are different. Every one has a birth date and a document number. A match on Luis Antonio Hernandez Zea, born 7 May 1960, with a cedula and two passport numbers on the row, was never ambiguous. For these the stated reasons left are death and dissolution, and the release does not say which is which. A well-identified name coming off the list says nothing about the person's risk today. The two entities with no registration number are Largo Leasing Ltd. in the Cayman Islands and Trans Pacific World Leasing Limited in Vanuatu.

Removal from the SDN List ends the OFAC listing. It does not touch another authority's list, and we checked.

We compared the primary name of every removed subject with the UK Sanctions List (report date 8 October 2026), the UN consolidated list (generated 8 October) and the EU consolidated export (generated 22 September). The test required every token of a name to appear in one entry.

Two subjects matched, and both matches agree on birth date.

• Tibisay Lucena Ramirez, born 26 April 1959, whose UK statement of reasons describes her as former President of Venezuela's National Electoral Council. UK Unique ID VEN0017, designated 31 December 2020.
• Aliaksei Auramenka, born 11 May 1977, listed by the UK as Minister for Transport and Communication of Belarus. UK Unique ID BEL0100, designated 21 June 2021. The EU export also holds him, under reference EU.6455.84, with the same birth date.

Both carry full identifiers on their OFAC rows. The release does not explain their removal, and we do not guess.

Nothing among the 41 Iraq-programme names matched in the UN or EU files. That is a limit of the test, not a clearance: an exact-token test misses transliterations and reordered names, and Iraq-programme names are mostly transliterations.

Three of the 22 updates are vessels. For the two renamed ones, the new entry records the former flag but not the former name.

A cargo file holding LA PEARL or VICTORIA will no longer match anything on the SDN List by name. The IMO number carries over, and it is the identifier to key on. For NAVARZ the name stays, but four alias rows were removed: ELITE, NAPOLI, NOAH and VOYAGER.

One of those names deserves a note. ELITE was an alias of two different ships, NAVARZ and LA PEARL, with different IMO numbers. A stored alert on "ELITE" pointed at either hull and cannot be resolved by name. Both ELITE rows are gone.

The other 19 updates are the clean-up Treasury describes. All 16 Mexican individuals now carry a C.U.R.P., the national personal ID number, and several lost street addresses and alternative birth dates. Javier Torres Felix lost four aliases, among them COMPADRE and EL JT, and his Culiacan address. Hector Luis Palma Salazar lost two of his three birth dates and became Jesus Hector Palma Salazar, the old primary name demoted to an alias.

The three Hong Kong companies, AE International Trade Co Limited, Hin Yun Trading Company Limited and Qian Xi Long Trading Co Limited, lost their street addresses and are now located only as "Hong Kong, China". Hin Yun and Qian Xi Long shared one address on Lockhart Road in Wanchai. A rule that flagged "same address as a listed party" no longer links them.

1. Diff by row, report by subject. Expect 199 rows gone from a data file and 125 subjects to explain, plus the entries that were rewritten.
2. Re-open stored decisions on the removed names, keep the original block record, and log the removal with its date.
3. Check the UK, EU and UN lists before releasing a counterparty. Two of the 125 are still listed in the UK.
4. Re-key the three ships on IMO number, 9174660, 9113379 and 9079078.
5. Refresh stored aliases for the 16 Mexican individuals and the three Hong Kong companies, so recall does not drift.

The Federal Register notice of 7 October (91 FR 64224) is a different action: it publishes the removals of 27 July. We did not find the 5 October entries in it.

A delisting only helps you if the old decision can be found and re-opened. ScreenVeritAI saves each screening as a point-in-time record, and scheduled re-screens run a stored counterparty list again on a daily, weekly or monthly schedule. See batch screening.

This is a report of what OFAC and Treasury published on 5 October 2026, plus our own count of OFAC's page and our comparison with three public list files. We have not checked how any screening vendor, including ours, handled the 5 October entries, and we make no statement about our own data.

We do not know why any individual entry was removed. The release gives three reasons by category, introduced with "include". The UK, EU and UN comparison is an exact-token test on primary names; it can miss a subject. The EU file was generated on 22 September, so a later EU change is not reflected. A removal ends one listing and gives no opinion on whether the party is risky today.