OFAC Sanctions List

The Office of Foreign Assets Control (OFAC) administers the most consequential sanctions regime in the world. Its reach extends well beyond US borders — non-US companies, banks, and individuals can face severe penalties, loss of correspondent banking access, and exclusion from the US dollar system for dealings with OFAC-listed parties. This page explains what the OFAC lists are, who they affect, and what is at stake.

What is OFAC?

OFAC is an office within the US Department of the Treasury. It administers and enforces economic sanctions based on US foreign policy and national security goals, targeting countries, regimes, terrorists, narcotics traffickers, weapons proliferators, and other designated threats.

What makes OFAC unusual is the extraterritorial reach of its enforcement. Because the US dollar underpins the majority of international trade and virtually all cross-border dollar transactions clear through US correspondent banks, OFAC sanctions have practical consequences for businesses and financial institutions worldwide — regardless of where they are incorporated or where a transaction takes place.

The SDN List (Specially Designated Nationals and Blocked Persons)

The SDN List is OFAC's primary sanctions list. It identifies individuals, companies, vessels, aircraft, and other entities whose assets are blocked (frozen) and with whom US persons are generally prohibited from dealing.

Being placed on the SDN List has immediate, severe consequences:

• Full asset freeze — all property and interests in property within US jurisdiction must be blocked and reported to OFAC
• Transaction prohibition — US persons may not engage in any transaction or dealing with the listed party, directly or indirectly
• The 50 Percent Rule — any entity owned 50% or more (in aggregate) by one or more SDNs is itself considered blocked, even if it does not appear on the list by name[2]
• Secondary sanctions exposure — non-US persons who engage in significant transactions with SDNs risk being designated themselves, losing access to US markets, or being cut off from the US financial system

The Consolidated Non-SDN List

The Consolidated Non-SDN List combines several smaller OFAC programs into a single searchable file. While these parties are not subject to the full blocking that applies to SDNs, they are still subject to significant restrictions that vary by program:

• Sectoral Sanctions Identifications (SSI) — restrictions on debt, equity, and certain transactions with parties in targeted sectors of sanctioned economies (primarily Russian energy, finance, and defence)
• Non-SDN Chinese Military-Industrial Complex Companies (CMIC) — US persons are prohibited from purchasing or selling publicly traded securities of listed Chinese companies linked to China's military-industrial complex
• Foreign Sanctions Evaders (FSE) — foreign persons determined to have facilitated deceptive transactions or sanctions evasion on behalf of persons subject to US sanctions
• Non-SDN Menu-Based Sanctions (NS-MBS), Capta List (CAP), and Palestinian Legislative Council (PLC) — additional program-specific restrictions including correspondent banking prohibitions

Who needs to check the OFAC list?

All US persons — including citizens, permanent residents, US-incorporated entities, and anyone physically present in the United States — are required to comply with OFAC regulations. But the practical reach extends much further.

US persons and entities

• Banks and financial institutions — must screen all transactions, freeze blocked assets, and file blocking reports with OFAC within 10 business days
• Exporters and importers — must ensure goods, services, and technology do not reach sanctioned parties or embargoed destinations
• Universities and research institutions — must screen international collaborators, visiting scholars, technology transfers, and equipment purchases. Federal funding agencies increasingly require documented sanctions compliance
• Law firms, consultancies, and accounting firms — must screen clients and counterparties; providing professional services to SDNs is itself a prohibited transaction
• Insurers and reinsurers — cannot provide coverage for transactions or assets involving sanctioned parties
• Real estate professionals — OFAC has pursued individual real estate investors for purchasing and selling property owned by sanctioned persons, with a $4.7 million settlement in 2025[1]

Non-US persons and companies

Through secondary sanctions, OFAC extends its reach to non-US persons and entities around the world. The consequences are not theoretical:

• SDN designation — non-US persons who materially assist, act on behalf of, or engage in significant transactions with SDNs can be designated as SDNs themselves, resulting in asset freezes and exclusion from all US markets[4]
• Loss of correspondent banking — foreign banks that process transactions involving sanctioned parties risk having their US correspondent accounts severed, effectively cutting them off from the US dollar clearing system. In February 2026, the US proposed severing Swiss bank MBaer from the US financial system over alleged sanctions evasion involving Iranian, Russian, and Venezuelan entities — the bank subsequently entered liquidation[5]
• Exclusion from US markets — non-US companies that violate secondary sanctions can lose the ability to transact in US dollars, access US capital markets, or do business with US counterparties
• Supply chain contagion — companies in Asia, the Middle East, Africa, and Latin America face indirect exposure even without operations in sanctioned jurisdictions, because their banks, customers, or suppliers may have US touchpoints that create secondary risk[4]

Enforcement: what OFAC penalties look like in practice

OFAC imposed $262.6 million in civil penalties across 13 enforcement actions in 2025 alone.[1] Penalties range from tens of thousands of dollars for small businesses to hundreds of millions for systemic violations.

Two patterns are worth noting. First, OFAC increasingly pursues individuals and small firms, not just large banks — the $4.7 million penalty against a single real estate investor demonstrates this. Second, OFAC gives significant credit for voluntary self-disclosure: companies that discover and report their own violations typically face substantially lower penalties than those that are caught.

Strict liability: intent does not matter

OFAC operates on a strict liability basis. A civil violation can occur even without knowledge or intent to violate sanctions.[3] This is different from most regulatory frameworks, where intent or negligence must be established.

In practice, this means:

• "We didn't know they were sanctioned" is not a defence
• "Our compliance vendor missed it" is not a defence
• "The transaction was routed through an intermediary" is not a defence
• The only reliable mitigation is a documented, systematic screening process — which OFAC considers a mitigating factor when assessing penalties[9]

OFAC's compliance framework

OFAC has published a formal framework outlining what it considers an effective sanctions compliance program. The framework identifies five essential components:[9]

• Management commitment — senior leadership must allocate adequate resources, approve the compliance program, and ensure direct reporting lines
• Risk assessment — a systematic review of customers, products, services, supply chains, counterparties, and geographic exposure
• Internal controls — documented policies and procedures for screening, escalation, and recordkeeping
• Testing and auditing — regular independent evaluation of whether the program is actually working
• Training — ongoing education for relevant personnel on sanctions requirements and red flags

Organisations that implement programs aligned with this framework receive favourable consideration during enforcement actions, including potential mitigation of penalties. Organisations without any compliance program face the opposite: aggravated penalties.

How often is the OFAC list updated?

OFAC updates its lists on a rolling basis. New designations, delistings, and modifications can occur multiple times per week. There is no fixed schedule — updates are driven by policy actions, executive orders, and enforcement proceedings.

This means that a name screened last month may not be clean today. Ongoing or periodic rescreening is essential, especially for long-running commercial relationships, investment portfolios, and institutional partnerships. Sanctions Checklist downloads the latest OFAC data daily through automated processes — you can verify exact timestamps on the data sources page.

OFAC's own search tool vs third-party screening

OFAC provides a free search tool at sanctionssearch.ofac.treas.gov that covers the SDN List and related OFAC lists. It is the authoritative source and should always be referenced as the primary record.

However, OFAC is only one of many sanctions regimes. The UN Security Council, European Union, UK (OFSI), Australia (DFAT), Canada, Switzerland (SECO), Singapore (MAS), and Japan (METI) all maintain their own sanctions and restricted-party lists. A party not listed by OFAC may be designated by the EU or UN, and vice versa. The Bureau of Industry and Security (BIS) maintains separate export control lists (Entity List, Denied Persons List, Unverified List) that overlap but are distinct from OFAC.

Checking each authority separately is time-consuming and creates gaps. Third-party tools like Sanctions Checklist aggregate multiple lists into a single query, reducing the risk of missing a designation you didn't think to check. Our comparison page explains how different providers approach this and what they charge.