The Non-SDN Iran Sanctions Act (NS-ISA) List is a public sanctions roster maintained by the Office of Foreign Assets Control (OFAC) within the U.S. Department of the Treasury, identifying foreign persons against whom the Secretary of State has imposed sanctions under the Iran Sanctions Act of 1996 (ISA, Public Law 104-172), as amended by the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA, P.L. 111-195), the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHRA, P.L. 112-158), and the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA, Subtitle D of the FY2013 NDAA). The list exists because ISA-based sanctions are "menu" measures—prohibitions on specific U.S.-nexus privileges—rather than asset blockings, and therefore cannot be enforced through the Specially Designated Nationals (SDN) List, which is reserved for persons whose property is frozen under IEEPA-based authorities.
Procedurally, a placement on the NS-ISA List follows a State Department determination that a foreign person has engaged in sanctionable conduct enumerated in ISA Section 5, including investment in Iran's petroleum sector exceeding statutory thresholds, sale of refined petroleum products to Iran, or provision of goods, services, or technology that enhance Iran's ability to develop petroleum resources or domestic refining capacity. After interagency review and, where applicable, consultation with the targeted person's government of jurisdiction, the Secretary of State selects no fewer than five sanctions from the menu in ISA Section 6(a). OFAC then publishes the name, identifying information, and the specific menu items selected in the Federal Register and on the NS-ISA List, which is downloadable in the same SDN-style data formats (DEL, FF, XML) as Treasury's other consolidated lists.
The Section 6(a) menu contains twelve possible measures, ranging from denial of Export-Import Bank assistance, export license restrictions, and a prohibition on U.S. financial institution loans above $10 million, to bans on participation in U.S. government procurement, restrictions on foreign exchange and banking transactions subject to U.S. jurisdiction, denial of property rights in the United States, import bans, and prohibitions on principal executives of the sanctioned entity entering the United States. Because the consequences are calibrated rather than total, the NS-ISA designation can be partially lifted, modified, or supplemented without removing the person from the list. Waivers under ISA Section 9(c) and 4(c) permit the President to suspend application against specific persons or transactions on national-interest grounds, and these waivers are tracked in the corresponding Federal Register notices.
Contemporary examples include the designation of the China-based Zhuhai Zhenrong Corporation in January 2012 for supplying refined petroleum to Iran—the first ISA action against a Chinese entity—and concurrent measures against Singapore's Kuo Oil and the UAE's FAL Oil. The Belarusian state firm Belarusneft was placed on the list in March 2011 for a roughly $500 million investment in Iran's Jofeir oilfield. Following the U.S. withdrawal from the Joint Comprehensive Plan of Action in May 2018 and the snapback announced under National Security Presidential Memorandum-11, the Trump administration revived ISA-based authorities; subsequent designations have flowed primarily through Executive Order 13846 (August 2018), which consolidates and reissues ISA, ITRSHRA, and IFCA authorities while retaining the NS-ISA listing mechanism for non-blocking penalties.
The NS-ISA List should not be confused with the SDN List, where Iran-related entries appear under program tags such as [IRAN], [IRAN-EO13599], [SDGT], or [IFSR] and trigger asset-blocking and the comprehensive prohibition on U.S.-person dealings under 31 C.F.R. Part 560. Nor is it identical to the Non-SDN Menu-Based Sanctions List (NS-MBS List), which catalogues menu sanctions imposed under authorities other than ISA—most prominently the Countering America's Adversaries Through Sanctions Act (CAATSA) Section 235 for Russia-related conduct and EO 13662. The Non-SDN Palestinian Legislative Council List, the Foreign Sanctions Evaders List, and the Sectoral Sanctions Identifications List are likewise distinct OFAC products, each tied to particular statutory or executive authorities.
A persistent controversy concerns the list's extraterritorial reach. European Union Council Regulation (EC) No 2271/96, the Blocking Statute, prohibits EU operators from complying with ISA-derived measures and was updated in August 2018 specifically to address the post-JCPOA snapback. China and Russia have routinely rejected ISA designations as inconsistent with sovereign equality and have continued petroleum-sector engagement with Tehran through non-dollar settlement channels. A further complication is that some NS-ISA listees have subsequently been added to the SDN List under separate authorities (for example, EO 13224 counterterrorism designations or EO 13599 Government of Iran blocking), producing dual status; in such cases the SDN blocking obligation dominates operationally even though the NS-ISA menu sanctions remain formally in force.
For the working practitioner—a sanctions compliance officer, export-control counsel, trade-finance banker, or foreign-ministry desk officer—the NS-ISA List functions as an early-warning indicator and as a precise statement of which U.S.-nexus privileges have been withdrawn from a counterparty. Unlike SDN status, NS-ISA placement does not automatically taint downstream transactions or implicate the 50 Percent Rule, but it materially constrains access to U.S. capital markets, Ex-Im financing, federal procurement, and dollar correspondent banking for the named person. Diligence workflows that screen only the SDN List will miss these counterparties; reputable screening tools therefore ingest the consolidated non-SDN files alongside the SDN file, and prudent counsel treats NS-ISA placement as a strong signal of broader Iran-nexus exposure that may evolve into full blocking designation.
Example
In January 2012 the U.S. State Department placed Zhuhai Zhenrong Corporation on the NS-ISA List for selling roughly $500 million in refined petroleum to Iran, barring it from U.S. government procurement and Ex-Im financing.