JURISDICTION SCREENING GUIDES · GUIDEUPDATED 2026-08-20
Jurisdiction Screening Guides
OFAC Screening: SDN List and Consolidated Sanctions List Workflow
What OFAC screening covers — the SDN List, the Consolidated (non-SDN) Sanctions List, the 50 percent rule, secondary sanctions — and how to run and document an OFAC check.
OFAC screening is the control that checks people, companies, vessels and aircraft against the sanctions lists published by the Office of Foreign Assets Control, a bureau of the US Department of the Treasury. OFAC administers and enforces US economic and trade sanctions under authorities that include the International Emergency Economic Powers Act, the Trading with the Enemy Act and programme-specific statutes, implemented through executive orders and the regulations at 31 CFR Chapter V. The obligation binds all US persons — US citizens and lawful permanent residents wherever they are located, entities organised under US law including their foreign branches, and anyone physically present in the United States — and reaches non-US companies in practice whenever a transaction touches the US financial system, US-origin goods, or a US person. Civil liability is strict: a violation can be penalised without any showing of intent or knowledge, and penalty ceilings are adjusted for inflation each year. This page sets out which OFAC lists to screen, how the 50 percent rule extends a designation to companies that are not themselves named, and how to review and evidence a potential match.
What this workflow covers
SCOPE- Screen the Specially Designated Nationals and Blocked Persons List (SDN List) — the core list, whose designations block all property and interests in property in US jurisdiction and prohibit dealings by US persons.
- Screen the Consolidated Sanctions List as well, which aggregates OFAC's non-SDN lists: the Sectoral Sanctions Identifications (SSI) List, the Non-SDN Menu-Based Sanctions (NS-MBS) List, the Correspondent Account or Payable-Through Account Sanctions (CAPTA) List, the Foreign Sanctions Evaders (FSE) List, the Non-SDN Palestinian Legislative Council List and the Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List.
- Apply the 50 percent rule: OFAC treats any entity owned 50 percent or more, directly or indirectly, in the aggregate, by one or more blocked persons as blocked itself, even though it is not named on the SDN List.
- Match on identifiers, not name strings alone — SDN entries carry aliases and 'a.k.a.' values, dates and places of birth, nationalities, passport and national identification numbers, addresses, and for vessels the IMO number, call sign and flag.
- Distinguish blocking from restriction: an SDN designation freezes property outright, while SSI, NS-MBS, CAPTA and NS-CMIC listings impose narrower, menu-specific or sector-specific prohibitions rather than a full block.
- Account for secondary sanctions, which threaten non-US persons with designation or loss of access to the US market for significant transactions with certain sanctioned parties, even where no US nexus exists.
- Check whether a general licence authorises the activity before assuming a prohibition, and apply for a specific licence where none does; wind-down and humanitarian authorisations are common and time-limited.
- Screen against the current list version and record which version was used — OFAC publishes updates whenever designations, amendments and delistings are made, frequently several times a month.
- Block or reject as the programme requires, and file the corresponding report with OFAC within the required period; blocked property also carries an annual reporting obligation.
- Build the programme around OFAC's Framework for Compliance Commitments — management commitment, risk assessment, internal controls, testing and auditing, and training — because it is the yardstick used in enforcement.
Key statistics
DATA- Administering authority
- Office of Foreign Assets Control, U.S. Department of the Treasury
- U.S. Department of the Treasury
- Primary legal basis
- International Emergency Economic Powers Act; 31 CFR Chapter V
- U.S. Code and Code of Federal Regulations
- Ownership aggregation threshold
- 50% or more, directly or indirectly, in the aggregate
- OFAC Revised Guidance on Entities Owned by Blocked Persons
- Liability standard
- Strict civil liability — intent is not required
- U.S. Department of the Treasury, OFAC
Compliance glossary
TERMS- SDN (Specially Designated National)
- An individual, entity, vessel or aircraft named on OFAC's Specially Designated Nationals and Blocked Persons List. All property and interests in property of an SDN within US jurisdiction are blocked, and US persons are generally prohibited from any dealings with them.
- Blocked property
- Property and interests in property subject to a US asset freeze. Blocked property cannot be transferred, paid, exported, withdrawn or otherwise dealt in, and must generally be placed in a blocked interest-bearing account and reported to OFAC.
- 50 percent rule
- OFAC's ownership rule: an entity owned 50 percent or more, directly or indirectly, in the aggregate, by one or more blocked persons is itself blocked, even if it does not appear on any OFAC list.
- Sectoral sanctions (SSI)
- Restrictions on specified activities — such as new debt, new equity or certain services — with entities operating in designated sectors of a target economy. Parties are named on the Sectoral Sanctions Identifications List, and their property is not blocked outright.
- Secondary sanctions
- Measures directed at non-US persons for conduct outside US jurisdiction, exposing them to designation or restricted access to the US market for significant transactions with specified sanctioned persons or sectors.
- OFAC general licence
- A published authorisation permitting a category of transactions that a sanctions programme would otherwise prohibit, without the need to apply individually. Where no general licence applies, a specific licence must be sought from OFAC.
Authoritative references
SOURCES- 01Specially Designated Nationals and Blocked Persons List (SDN List)
U.S. Department of the Treasury, OFAC
- 02Consolidated Sanctions List and other OFAC sanctions lists
U.S. Department of the Treasury, OFAC
- 03Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property Are Blocked (the 50 Percent Rule)
U.S. Department of the Treasury, OFAC
- 04A Framework for OFAC Compliance Commitments
U.S. Department of the Treasury, OFAC
- 05Sanctions Programs and Country Information
U.S. Department of the Treasury, OFAC
Expert perspective
NOTE“OFAC operates on strict liability — intent is not a defense — and its secondary sanctions reach means exposure doesn't stop at the U.S. border.”
Frequently asked questions
Q&A- What is the OFAC SDN list?
- The Specially Designated Nationals and Blocked Persons List is OFAC's core sanctions list. It names individuals, companies, vessels and aircraft whose property and interests in property within US jurisdiction are blocked, and with whom US persons are generally prohibited from dealing. Entries include aliases, dates of birth, identification numbers and addresses, and each is tagged with the sanctions programme under which it was designated.
- What is the difference between the SDN List and the OFAC Consolidated Sanctions List?
- The SDN List blocks property and prohibits dealings outright. The Consolidated Sanctions List gathers OFAC's non-SDN lists, where the restrictions are narrower — the SSI List restricts specific sectoral activity, CAPTA restricts correspondent account relationships, NS-MBS applies selected menu-based measures, and NS-CMIC restricts securities dealings. Being on a non-SDN list is not the same as being blocked, but it still constrains what is permitted.
- What is OFAC's 50 percent rule?
- Under OFAC's guidance on entities owned by blocked persons, any entity owned 50 percent or more, directly or indirectly, in the aggregate, by one or more blocked persons is itself blocked, whether or not it appears on the SDN List. Ownership is aggregated across multiple blocked owners. This is why ownership tracing, not just name screening, is a required part of an OFAC check.
- Who has to comply with OFAC sanctions?
- All US persons: US citizens and lawful permanent residents wherever located, entities organised under US law and their foreign branches, and any person physically in the United States. Some programmes reach further, covering foreign subsidiaries of US companies. Non-US companies are also affected whenever a transaction has a US nexus, such as US dollar clearing, US-origin goods or the involvement of a US person.
- Are non-US companies subject to OFAC screening?
- Frequently, yes. A non-US company falls within reach when its transaction has a US nexus — payment cleared in US dollars through a US correspondent bank, US-origin goods or technology, US persons involved in the deal — and separately through secondary sanctions, which can expose a non-US party to designation for significant dealings with certain sanctioned persons even without a US nexus.
- What are OFAC secondary sanctions?
- Secondary sanctions target non-US persons for conduct outside US jurisdiction. Rather than prohibiting the transaction directly, they threaten consequences — designation on the SDN List, loss of correspondent banking access, or menu-based measures — where a non-US party knowingly engages in significant transactions with specified sanctioned persons or sectors. They are the mechanism by which US programmes reach global supply chains.
- How often is the OFAC SDN list updated?
- There is no fixed schedule. OFAC publishes changes whenever designations, amendments or delistings are made, which in practice is often several times a month and sometimes several times a week. Because a designation takes effect on publication, screening programmes should refresh against the current list rather than a periodic snapshot, and should record which list version a decision was based on.
- What should you do if you find a true OFAC match?
- Stop the transaction before it completes and escalate to compliance. Depending on the programme, the property must either be blocked in an interest-bearing account or the transaction rejected, and the corresponding report filed with OFAC within the prescribed period. Do not notify the counterparty of the reason where doing so would tip off, and preserve the screening evidence supporting the determination.
- How do you clear an OFAC false positive?
- Compare discriminating identifiers rather than the name alone. An SDN entry usually carries a date or place of birth, nationality, passport or national identification number, or a registered address; a documented mismatch on strong identifiers is what clears a hit. Record which identifiers were compared, what differed, who reviewed it and when, so the clearance is auditable rather than a silent dismissal.
- Can OFAC screening run alongside EU, UK and UN checks?
- Yes, and it usually should. Most organisations have exposure to more than one regime, and the lists do not mirror each other — a party designated by OFAC may not be listed in the EU or the UK, and the reverse is equally common. Running the jurisdictions in one pass against a consistent set of identifiers produces one reviewable record rather than several partial ones.
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