OFAC SDN List — What Is It, How to Check It, and How to Get Removed

What Is the OFAC SDN List?

The OFAC SDN list — formally known as the Specially Designated Nationals and Blocked Persons List — is one of the most consequential regulatory tools in the global financial system. Maintained by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), this OFAC sanctions list identifies individuals, corporations, vessels, aircraft, and government entities whose assets are frozen and with whom U.S. persons are prohibited from transacting.

The list is not merely a U.S. concern. Because the U.S. dollar dominates global trade and finance, appearing on the OFAC list effectively cuts a person or entity off from the international financial system. Banks worldwide — even those outside the United States — routinely screen against the SDN list to avoid correspondent banking consequences and secondary sanctions exposure.

As of 2026, the SDN list contains over 12,000 entries spanning individuals, businesses, terrorist groups, drug traffickers, proliferators of weapons of mass destruction, cybercriminals, and governments subject to comprehensive sanctions programs.

How the OFAC SDN List Works

OFAC designates parties to the SDN list under various legal authorities, including executive orders, statutes such as the International Emergency Economic Powers Act (IEEPA), and specific congressional legislation. Each designation triggers immediate legal obligations for all U.S. persons:

• Asset blocking: Any property or interests in property of an SDN that comes within U.S. jurisdiction must be immediately frozen
• Transaction prohibition: U.S. persons cannot engage in any transactions with SDNs without a specific OFAC license
• 50% Rule: Entities owned 50% or more by one or more SDNs are themselves treated as blocked, even if not explicitly listed
• Reporting obligation: U.S. persons who block SDN property must report the action to OFAC within 10 days

The OFAC SDN Search: How to Check the List

OFAC provides a free, publicly accessible OFAC SDN search tool at its official website (ofac.treasury.gov/sanctions). Users can search the Specially Designated Nationals List by name, address, country, or identification number. The tool returns exact matches and near-matches to help compliance officers conduct due diligence.

In addition to the SDN list, OFAC maintains several other sanctions lists, including the Consolidated Sanctions List (Non-SDN), which includes individuals subject to specific prohibitions but whose assets are not necessarily blocked. Thorough OFAC list compliance screening typically covers all these databases.

Financial institutions and multinational companies typically automate this process using commercial screening software (such as World-Check, LexisNexis Bridger, or Dow Jones) that checks against the SDN list in real time during customer onboarding, wire transfers, and trade finance transactions.

Consequences of Being on the OFAC SDN List

The consequences of designation on the OFAC sanctions list are severe and multidimensional. They extend far beyond the United States and affect virtually every aspect of a person’s or company’s financial and commercial life.

Category	Consequence	Real-World Examples
Financial	All U.S.-held assets blocked immediately; no U.S. financial institution may process transactions; crypto exchanges face enforcement for processing SDN transactions	Rosneft and Lukoil (Russia) — sanctioned Oct 2025; Iranian shadow fleet banking accounts frozen
Business	Prohibited from all trade and services with U.S. persons; 50% Rule blocks subsidiary entities; global ripple effect via USD correspondent banking	6 Hong Kong officials designated under EO 13936 in 2025, cutting access to U.S. financial markets
Travel	Vessels and aircraft blocked from U.S. ports; individuals effectively barred from the U.S. financial system and often face entry restrictions	Iran shadow fleet vessels blocked from U.S. ports and unable to obtain insurance from Lloyd’s-affiliated insurers
Property Seizure	U.S. persons must freeze and turn over SDN property to OFAC; no use, transfer, or sale without specific license	Colombian cartel assets seized; drug trafficking networks’ U.S. real estate holdings frozen
Reputational	Permanent public record; banks globally screen and reject SDN-linked parties; severe disruption to legitimate business operations	Southeast Asia fraud networks (Myanmar/Cambodia) designated in 2025 — cut off from all correspondent banking

Who Gets Added to the SDN List?

OFAC designates parties under dozens of sanctions programs targeting specific geopolitical and security threats. Recent 2025 additions included:

• Russian energy companies (Rosneft, Lukoil) — designated in October 2025 under Ukraine-related sanctions
• Colombian President Gustavo Petro — added October 2025 under counternarcotics authorities
• Hong Kong officials — 6 persons designated under Executive Order 13936 for undermining democracy
• ICC-related parties — 15 total designations including judges and prosecutors for Israel-related investigations
• Southeast Asia scam networks — Myanmar/Cambodia-based organizations targeting U.S. victims

The SDN Removal Process: How to Get Off the OFAC List

Getting removed from the OFAC SDN list (known as “delisting”) requires submitting a formal petition to OFAC demonstrating that the basis for designation no longer applies. This process is complex, technical, and typically requires experienced OFAC SDN removal lawyers.

Step	Action Required	Estimated Timeline
1. Eligibility Assessment	Review the specific designation authority, grounds for listing, and available legal arguments for removal	1–2 weeks
2. Evidence Gathering	Compile documentation showing changed circumstances, dissociation from sanctioned activities, or factual errors in the designation	2–6 weeks
3. Petition Drafting	Prepare a formal delisting petition with legal arguments, factual narrative, and supporting exhibits submitted via OFAC’s online portal	2–4 weeks
4. OFAC Review	OFAC evaluates the petition, may request additional information, and coordinates with other government agencies	3–18 months
5. Decision	OFAC issues a decision: removal via Federal Register notice (assets unblocked) or denial with opportunity to supplement the petition	Ongoing after review
6. OFAC License (interim)	While delisting petition is pending, it may be possible to obtain a specific OFAC license to unblock assets or conduct limited transactions	30–90 days for license

The Liste SDN: International Dimension

The liste SDN (as it is known in French-speaking markets) has profound international implications. European banks, Middle Eastern financial institutions, and Asian trading companies all screen against the OFAC SDN list because failure to do so risks losing access to the U.S. dollar clearing system.

Secondary sanctions add another layer of complexity: non-U.S. parties who knowingly facilitate SDN-prohibited transactions may themselves face designation or restrictions on their access to U.S. markets. This extraterritorial reach makes the SDN list one of the most powerful unilateral tools in international economic statecraft.

Errors and False Positives on the SDN List

A significant and under-discussed problem is SDN list false positives — situations where innocent individuals or companies are incorrectly matched to SDN entries due to similar names, shared addresses, or screening algorithm failures. These cases require immediate legal action to correct and can cause severe harm including account freezes and business disruptions.

OFAC recognizes this issue and provides a process for non-listed parties who have been incorrectly identified as SDNs to seek a formal determination that they are not the intended designee.

How Sanctions Lawyers Can Help

Whether you have been designated on the OFAC SDN list, suspect a false positive match, need to navigate the complex delisting process, or require an OFAC license to conduct otherwise-prohibited transactions, experienced sanctions lawyers are essential. Our team at Sanctions Lawyers has handled hundreds of OFAC matters, from emergency asset freeze response to multi-year delisting campaigns.