Reading an OFAC Action Package End-to-End
A document-by-document workflow for reading an OFAC sanctions action package — press release, SDN delta, General Licenses, FAQs, and allied coordination.
The Components of an OFAC Action
When the Office of Foreign Assets Control (OFAC) rolls out a sanctions action, the public-facing event — a press release on Treasury.gov — is the tip of a coordinated documentary package. A complete action typically comprises seven artifacts released within minutes of one another: (1) a Treasury press release summarizing the policy rationale; (2) a Specially Designated Nationals (SDN) List update file, distributed in XML, CSV, and PDF; (3) a Recent Actions notice on the OFAC website itemizing each designation; (4) one or more General Licenses (GLs) authorizing wind-down or humanitarian transactions; (5) updated or new Frequently Asked Questions (FAQs); (6) where rulemaking is involved, a Federal Register notice; and (7) often a coordinated statement from the State Department, the White House, or allied jurisdictions (UK OFSI, EU, Canada, Australia).
Reading the package end-to-end means treating these as a single legal instrument. The press release tells you why; the SDN update tells you who; the General Licenses tell you what is still permitted; and the FAQs tell you how OFAC will interpret ambiguity. A compliance officer who reads only the press release will miss the operative compliance triggers, which sit in the SDN entries' identifier fields and in the GL paragraph numbering.
The Legal Authorities Cited
Every designation rests on a statutory and executive authority chain. The SDN entry's [program tag] — for example [UKRAINE-EO13662], [SDGT], [IRAN], [RUSSIA-EO14024] — points to the underlying executive order. Executive Order 14024 of April 15, 2021, authorizing sanctions against persons engaged in harmful foreign activities of the Government of the Russian Federation, is the dominant Russia authority post-2022. EO 13224 of September 23, 2001, anchors counterterrorism designations. EO 13818 of December 20, 2017, implements the Global Magnitsky Human Rights Accountability Act (Pub. L. 114-328, Subtitle F).
The statutory layer sits beneath the executive orders: the International Emergency Economic Powers Act (IEEPA, 50 U.S.C. §§1701–1708), the National Emergencies Act (50 U.S.C. §1601 et seq.), and program-specific statutes such as the Countering America's Adversaries Through Sanctions Act (CAATSA, Pub. L. 115-44) and the Caesar Syria Civilian Protection Act (Pub. L. 116-92, Title LXXIV). Designations under Section 1(a)(i) versus Section 1(a)(ii) of an EO matter operationally because they determine whether the 50 Percent Rule of OFAC's August 13, 2014 guidance attaches automatically to subsidiaries.
Decoding the SDN Entry
A single SDN entry can run to hundreds of fields. The critical ones are: primary name and aliases (a.k.a., f.k.a., n.k.a.); date of birth and place of birth (for natural persons); passport, national ID, and tax identification numbers; Digital Currency Address fields (DCA-XBT, DCA-ETH, DCA-USDT, introduced systematically after the 2018 SamSam designation); vessel IMO numbers; aircraft tail numbers; and the Linked-To field that establishes ownership or control relationships.
The program tag is non-trivial. An entity tagged [RUSSIA-EO14024] and [SDNTK] simultaneously falls under two distinct authority chains, and a license issued under one does not authorize transactions under the other. Compliance screening tools that collapse multiple tags into a single match obscure this. The [SECONDARY SANCTIONS RISK] advisory flag, added systematically to Iranian and Russian entries, signals that non-U.S. persons transacting with the entity face menu-based secondary sanctions under CAATSA §228 or EO 13846.