Screening Glossary
What are OFAC's non-SDN lists (SSI, CAPTA, NS-MBS)?
A hit that is not on the SDN List is not automatically nothing. OFAC's non-SDN registers, among them the Sectoral Sanctions Identifications List, the CAPTA List of banks facing correspondent-account restrictions and the NS-MBS List, carry narrower prohibitions than a full asset freeze.
Updated
Most screening programmes are built around the SDN List and then discover a counterparty restricted in some other way. The non-SDN registers exist because sanctions policy often needs a scalpel: prohibit new debt and equity, close a correspondent account, or impose selected menu-based measures, while leaving the target otherwise able to trade. OFAC groups several of them into its Consolidated Sanctions List download. Two opposite errors follow, treating a non-SDN hit as blocking, or filing it as informational, and both are wrong.
What this workflow covers
- Ingest the non-SDN registers alongside the SDN List, and keep the prohibition text attached to each hit.
- An SSI hit under a debt directive leaves the relationship lawful but bars new debt beyond the stated tenor. Nothing is frozen.
- Parties move. A non-SDN listing today can become an SDN designation later, with the same identifiers and a completely different consequence, so record which list produced the hit and on what date.
- Commerce's Entity List, Denied Persons List and Unverified List sit under a different agency and a different statute.
Compliance glossary
- NS-MBS List
- The Non-SDN Menu-Based Sanctions List, naming parties on whom OFAC has imposed selected measures from a statutory menu rather than a full block.
- Correspondent account
- An account a foreign bank holds with a domestic bank to settle payments; restricting it cuts a bank off from a currency without freezing its assets.
Authoritative references
Questions
Frequently asked questions
What does an SSI hit actually stop us doing?
The Sectoral Sanctions Identifications List names entities operating in sectors of the Russian economy identified by OFAC directives, and the prohibition is whatever the relevant directive says: directives have covered new debt, new equity and certain services. It is not a blanket freeze, so the analyst needs the directive in front of them, not just a score.
What is the CAPTA List for?
It identifies foreign financial institutions for which opening or maintaining a US correspondent or payable-through account is prohibited or tightly conditioned. CAPTA entries are not SDNs, so that listing alone blocks no property.
Do we file a blocking report for a non-SDN hit?
Blocking reports apply to blocked property, and a non-SDN listing alone creates none. What these hits do require is a documented control decision showing that the specific prohibition was identified and applied to the transaction in front of you.
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