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SDN List Program Tag (e.g., [RUSSIA-EO14024])

Updated May 23, 2026

A bracketed identifier appended to each Specially Designated Nationals List entry that links the designation to the specific OFAC sanctions program and legal authority under which it was imposed.

A Specially Designated Nationals (SDN) List program tag is a short bracketed code—such as [RUSSIA-EO14024], [SDGT], [IRAN-EO13599], or [SDNTK]—appended to each name on the consolidated SDN List published by the U.S. Treasury Department's Office of Foreign Assets Control (OFAC). The tag identifies the specific sanctions program, and by extension the underlying legal authority, that supports the designation. OFAC administers these programs under a layered architecture of statutes (principally the International Emergency Economic Powers Act, 50 U.S.C. §§ 1701–1708; the Trading with the Enemy Act, 50 U.S.C. § 4301 et seq.; the Foreign Narcotics Kingpin Designation Act, 21 U.S.C. § 1901 et seq.; and program-specific laws such as the Countering America's Adversaries Through Sanctions Act of 2017) together with presidential executive orders that declare national emergencies and delegate blocking authority to the Secretary of the Treasury.

Procedurally, when OFAC's Office of Global Targeting prepares a designation package, the recommending analyst identifies which program authority best fits the conduct—for instance, malicious cyber activity, narcotics trafficking, weapons proliferation, or transnational criminal activity. The Director of OFAC, acting under delegated authority from the Secretary of the Treasury, signs the designation memorandum, and the entry is then published in the Federal Register and added to the SDN List in machine-readable formats (XML, CSV, DEL, and PDF). The program tag is appended in square brackets immediately after the name, aliases, and identifying information. A single individual or entity may carry multiple tags—reflecting designations under several programs simultaneously—and each tag references a distinct legal basis that must be independently maintained, defended in litigation, and considered when granting general or specific licenses.

The tags themselves follow a partly standardized convention. Country-based programs commonly use a country abbreviation followed by the executive order number, such as [VENEZUELA-EO13692] or [SYRIA]. Thematic programs use functional acronyms: [SDGT] for Specially Designated Global Terrorist (E.O. 13224), [SDNTK] for Significant Foreign Narcotics Trafficker Kingpin Act designations, [SDNT] for Specially Designated Narcotics Trafficker (E.O. 12978, the Colombia narcotics order), [NPWMD] for Non-Proliferation of Weapons of Mass Destruction (E.O. 13382), [CYBER2] for malicious cyber activity (E.O. 13694 as amended by E.O. 13757), [GLOMAG] for Global Magnitsky human-rights and corruption designations (E.O. 13818, implementing the Global Magnitsky Human Rights Accountability Act of 2016), and [TCO] for transnational criminal organizations (E.O. 13581). When Congress or the President issues a new executive order, OFAC creates a new tag; existing names may be retagged or have tags added during program reorganizations.

Contemporary practice has produced a dense thicket of tags. Following Russia's February 2022 invasion of Ukraine, President Biden issued Executive Order 14024 expanding the Russian Harmful Foreign Activities program; OFAC has since added thousands of names under [RUSSIA-EO14024], covering oligarchs, defense entities, the Wagner Group's commercial network, and third-country facilitators in the United Arab Emirates, Türkiye, and the People's Republic of China. The Iran program is fragmented across [IRAN], [IRAN-EO13599], [IRAN-HR], [IRGC], and [IFSR] tags, each carrying different licensing implications. The People's Republic of China–related tags include [CMIC-EO13959] for Chinese Military-Industrial Complex Companies and [PRC-MEU-EO13959]. Compliance officers at institutions such as HSBC, Standard Chartered, and Deutsche Bank screen against the full consolidated list daily and use the tags to determine which screening logic and licensing regime applies.

The program tag should not be confused with the SDN List itself, which is the consolidated record of blocked persons, nor with the Sectoral Sanctions Identifications (SSI) List, the Non-SDN Menu-Based Sanctions List, or the Non-SDN Chinese Military-Industrial Complex Companies List—each of which carries its own tag schema and imposes lesser restrictions than full blocking. The tag is also distinct from the OFAC program page, which contains the regulatory text at 31 C.F.R. Chapter V, and from the "Recent Actions" press release. Where the SDN entry blocks all property and interests in property of the designated party under the 50% rule articulated in OFAC's August 13, 2014 guidance, the tag tells the screening analyst which executive order and Code of Federal Regulations part govern the prohibition.

Edge cases arise frequently. A delisting petition under 31 C.F.R. § 501.807 must address each program tag separately; removal under one authority does not extinguish designations under another. Litigation such as Kadi v. Council (in the European context) and U.S. cases including Kindhearts for Charitable Humanitarian Development v. Geithner (N.D. Ohio, 2009) have probed the due-process implications of multi-authority designations. When executive orders are revoked or consolidated—as occurred when E.O. 13662 sectoral measures were absorbed into the post-2022 Russia architecture—OFAC issues recent-action notices retagging existing entries, sometimes producing transitional periods during which legacy tags coexist with new ones.

For the working practitioner—a sanctions compliance officer, an export-control lawyer, a foreign-ministry desk officer assessing extraterritorial reach, or a journalist tracing financial networks—the program tag is the indispensable entry point to the regulatory regime. It signals which general licenses (e.g., GL 8 series for energy transactions under the Russia program) may authorize otherwise prohibited dealings, which 50% rule analyses apply, whether secondary sanctions risk attaches, and which OFAC division to contact for specific licensing. Mastery of the tag taxonomy is the difference between mechanical name-screening and substantive sanctions analysis.

Example

After Yevgeny Prigozhin's death in August 2023, OFAC continued adding Wagner Group affiliates in the Central African Republic and Mali to the SDN List under the [RUSSIA-EO14024] and [GLOMAG] tags throughout 2023 and 2024.

Frequently asked questions

Yes. Many designees—particularly Russian oligarchs and Iranian Revolutionary Guard Corps affiliates—carry three or more tags reflecting independent designations under different executive orders. Compliance teams must analyze each tag separately, because a general license issued under one program does not authorize transactions prohibited under another, and delisting requires petitioning against each authority.
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