SANCTIONS LISTS AND WATCHLISTS EXPLAINED · GUIDEUPDATED 2026-09-04
Sanctions Lists and Watchlists Explained
OFAC Consolidated Sanctions List: 481 records that restrict rather than block
OFAC's non-SDN file: six lists, 481 records dated 27 July 2026, an empty FSE List, the download URLs, and why a hit means read the directive, not stop.
A party can be sanctioned by OFAC without being blocked, and the 481 records that say so sit in a file that screening pipelines routinely skip. The Consolidated Sanctions List is OFAC's single export for every programme that is not a blocking designation. Six non-SDN lists sit inside it: the Sectoral Sanctions Identifications List, the Non-SDN Menu-Based Sanctions List, the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions, the Foreign Sanctions Evaders List, the Non-SDN Palestinian Legislative Council List and the Non-SDN Chinese Military-Industrial Complex Companies List. Each rests on its own executive order or statute, so what a listing forbids differs from programme to programme; the record tells you who, the directive tells you what. OFAC publishes the combined file in the same formats and to the same data standards as the SDN List, whenever a change is made. At roughly 2.5 percent of the SDN List's size it is easy to leave out of a pipeline, which is exactly how the gap it covers stays open.
What this workflow covers
SCOPE- 481 records in the file downloaded on 4 September 2026, which carried publication date 27 July 2026
- Six lists inside: SSI (sectoral), NS-MBS (menu-based), CAPTA (correspondent and payable-through account), FSE (foreign sanctions evaders), NS-PLC (Palestinian Legislative Council) and NS-CMIC (Chinese military-industrial complex companies)
- The FSE List is empty: the last remaining name was removed on 18 December 2025
- Programme tags in the current file are dominated by UKRAINE-EO13662 (the sectoral programme), NS-PLC, CMIC-EO13959 and HKAA, and many records carry two or more tags
- Same schema as the SDN List: unique identifier, primary name, a.k.a. list, subject type, programme list, dates and places of birth, identity documents, addresses and remarks
- Files: CONS_PRIM.CSV (about 260 KB) and consolidated.xml (about 1 MB) from https://www.treasury.gov/ofac/downloads/consolidated/, plus CONS_ADVANCED.XML from the sanctions list service host
- Publication follows OFAC actions rather than a calendar, so the consolidated file's own date can be weeks older than the SDN file's
- Nothing here freezes property, and export-control listings belong to the Bureau of Industry and Security
- Typical false positives: large Chinese and Russian corporate groups on NS-CMIC and SSI whose names recur across dozens of legitimate subsidiaries and transliterations, and NS-PLC individuals with common Arabic names and, in several cases, only a year of birth
- A non-SDN match is a restriction signal, not a block: escalate it, do not auto-reject
Key statistics
DATA- Records on the Consolidated (non-SDN) list, file published 27 July 2026
- 481
- OFAC consolidated.xml publication header
- Constituent non-SDN lists
- 6 (SSI, NS-MBS, CAPTA, FSE, NS-PLC, NS-CMIC)
- OFAC Additional Sanctions Lists
- Names currently on the Foreign Sanctions Evaders List
- 0 — last name removed 18 December 2025
- OFAC Additional Sanctions Lists
Compliance glossary
TERMS- Non-SDN
- An OFAC listing that restricts specific conduct without blocking property. Non-SDN parties are named on the Consolidated Sanctions List and remain lawful counterparties for activity outside the scope of the applicable directive.
- SSI (Sectoral Sanctions Identifications List)
- Parties operating in designated sectors of a target economy, subject to directives restricting activity such as new debt, new equity or specified services. Property is not blocked.
- CAPTA List
- The List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions. Opening or maintaining such an account in the United States for a listed institution is prohibited or subject to strict conditions.
- NS-CMIC
- Non-SDN Chinese Military-Industrial Complex Companies List. US persons are restricted from dealing in publicly traded securities of listed companies; the companies themselves are not blocked.
- Directive
- The instrument that carries the operative prohibition for a sectoral or menu-based programme. The listing identifies the party; the directive says what is actually forbidden, so both must be read together.
Authoritative references
SOURCES- 01Additional Sanctions Lists (non-SDN lists)
U.S. Department of the Treasury, OFAC
- 02Consolidated non-SDN XML export
U.S. Department of the Treasury, OFAC
- 03Non-SDN Menu-Based Sanctions List (NS-MBS List)
U.S. Department of the Treasury, OFAC
- 04Non-SDN Chinese Military-Industrial Complex Companies List (NS-CMIC List)
U.S. Department of the Treasury, OFAC
- 05Sanctions List Service
U.S. Department of the Treasury, OFAC
Frequently asked questions
Q&A- What is actually in OFAC's Consolidated Sanctions List?
- One export of every non-SDN programme, so that a firm can screen the sectoral, menu-based, correspondent-account, evader, Palestinian Legislative Council and Chinese military-industrial listings without pulling six separate files. Each record keeps the programme tag that says which regime it belongs to, and that tag is the first thing to read on a hit.
- Is a hit on the Consolidated List as serious as an SDN hit?
- It is a different kind of serious. An SDN designation blocks property and prohibits dealings outright; a non-SDN listing imposes a narrower measure defined by its own programme, such as a restriction on new debt or equity, a specific menu-based sanction, a condition on maintaining a correspondent account, or a prohibition on dealing in securities. Read the applicable directive before deciding, rather than stopping everything or waving it through.
- How often does the Consolidated List change?
- Whenever OFAC acts on one of the six constituent programmes, with no fixed schedule. Non-SDN programmes move less often than blocking programmes, so the consolidated file's publication date is usually older than the SDN file's; on 4 September 2026 it was 27 July 2026. Refresh both files on the same cycle anyway.
- The FSE List is empty. Can we drop it from the pipeline?
- Keep it. The programme still exists; it simply holds no names since the last remaining entry was removed on 18 December 2025. A future designation would appear in the consolidated file with an FSE tag and no other warning, and a pipeline that stopped reading the tag would miss it.
- Where do we download the Consolidated List, and in which format?
- The CSV is at https://www.treasury.gov/ofac/downloads/consolidated/cons_prim.csv and the XML at https://www.treasury.gov/ofac/downloads/consolidated/consolidated.xml, both free and unauthenticated. The advanced XML, CONS_ADVANCED.XML, is served from the sanctions list service host and gives you structured identifiers instead of a remarks string.
- Does the 50 percent rule apply to SSI and other non-SDN listings?
- Not automatically. OFAC's 50 percent rule is written for entities owned by blocked persons; separate guidance treats entities owned 50 percent or more by SSI parties as themselves subject to the relevant directives. Because the treatment differs by programme, check the guidance for the programme tag on the record you matched rather than applying one rule across the file.
- We already screen SDN.CSV. Do we really need this file as well?
- With any US nexus, yes. The two files do not overlap: a party on the sectoral or Chinese military-industrial lists will not appear in SDN.CSV at all, and at 481 records the ingest cost is trivial next to the gap it closes. ScreenVeritAI screens the non-SDN consolidated file alongside the SDN List (it is a registered source on the coverage register), and the Quick Check keeps that result as a point-in-time evidence PDF.
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