The Specially Designated Nationals and Blocked Persons List (SDN List) is maintained by the Office of Foreign Assets Control (OFAC), a unit of the U.S. Department of the Treasury. It identifies individuals, companies, vessels, and aircraft that are owned, controlled by, or acting on behalf of sanctioned regimes, as well as non-state actors such as terrorist organizations, narcotics traffickers, cyber actors, and proliferators of weapons of mass destruction.
Designations are made under authorities including the International Emergency Economic Powers Act (IEEPA), the Trading with the Enemy Act, the Global Magnitsky Human Rights Accountability Act, and country-specific executive orders. Once a party is listed, all property and interests in property within U.S. jurisdiction (or in the possession of U.S. persons anywhere) are blocked, and U.S. persons are generally prohibited from transacting with them absent a specific or general license from OFAC.
A key operational rule is the "50 Percent Rule": any entity owned 50% or more, directly or indirectly, by one or more SDNs is itself treated as blocked, even if not separately named. This sweeps in large corporate networks, particularly in Russia and Iran cases.
Although the SDN List is a U.S. instrument, its extraterritorial reach is significant because of the centrality of the dollar in global finance and the threat of secondary sanctions against non-U.S. firms that knowingly facilitate significant transactions with listed parties. Foreign banks routinely screen against the SDN List to avoid losing U.S. correspondent banking relationships.
Delisting is possible through a petition process under 31 C.F.R. § 501.807, but typically requires the designated party to demonstrate a change in behavior, mistaken identity, or changed circumstances. Notable historical removals include several Russian oligarchs and, at various points, parties tied to Myanmar, Sudan, and Cuba policy shifts. Researchers should consult OFAC's searchable Sanctions List Search tool and the daily Recent Actions page for current designations.
Example
In April 2018, OFAC added Russian aluminum magnate Oleg Deripaska and his company Rusal to the SDN List under Ukraine-related authorities, triggering a global spike in aluminum prices before Rusal was delisted in January 2019.
Frequently asked questions
No. It binds all U.S. persons (citizens, permanent residents, U.S.-incorporated entities, and anyone in U.S. territory), and through secondary sanctions can penalize foreign firms dealing with listed parties.
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