Specially Designated Nationals and Blocked Persons List

The Specially Designated Nationals and Blocked Persons List, or SDN List, is OFAC's live administrative publication identifying persons and property treated as blocked under programme-specific law. Listing communicates a blocking consequence but is not its universal legal source, does not identify every blocked person and differs from OFAC's non-blocking lists.

Legal character and authority

The list consolidates identifiers and programme tags from country and thematic programmes. Statutes, executive orders and regulations establish designation criteria, blocking, exemptions, licensing and enforcement. OFAC publishes and administers many entries; State makes some designations reflected in OFAC data.

An entry's programme tag, statute, order, regulation, notice and licences determine its effect. The list is a publication and data service, not independent blocking authority. Some programmes block governments, categories or ownership interests without naming every affected person.

Reach is programme-specific. Rules commonly block property in the United States or possessed or controlled by United States persons and prohibit covered dealings by them. Foreign-person and secondary-sanctions exposure must be established separately.

Blocking, ownership and list distinctions

Blocking immobilises property without transferring title. The 50 Percent Rule blocks an unlisted entity owned, directly or indirectly, 50 per cent or more in aggregate by one or more blocked persons. Control, office or ownership below 50 per cent does not automatically block it under that rule, although other prohibitions may apply.

Non-SDN lists can impose sectoral, menu-based, investment, correspondent-account or other restrictions rather than blocking. Listed SDNs, unlisted category members, 50 Percent Rule entities, non-SDN restricted persons and secondary-sanctions exposure are distinct.

In 2011, Treasury amended Appendix A to 31 C.F.R. chapter V to replace its printed SDN entries with information on accessing the online list, and removed Appendix B, the separate blocked-vessel list. It did not abolish every sanctions appendix. OFAC now delivers live data through its Sanctions List Service. Its continuous change archive reaches back to 1994; that date is not the origin of SDN categories or predecessor lists (2011 final rule, pages 38534-38535; change archive).

Statecraft use and transmission

The list implements targeted measures involving states, officials, firms, armed groups, terrorism, proliferation, narcotics and cyber activity. Designation, publication, licensing and removal have a direct state nexus. Covered firms act as regulated intermediaries.

Financial institutions may restrict relationships for reasons extending beyond a legal duty to block. Treasury's 2023 De-Risking Strategy identifies profitability, risk appetite, compliance costs and regulatory uncertainty as drivers of broader withdrawal. This can extend practical exclusion, but mandatory United States compliance, foreign legal exposure and private risk decisions require separate evidence (Treasury strategy, pages 1-4).

Designation criteria and notice establish official allegations, not compellent purpose, humanitarian effect or success.

Procedure and review

Persons sanctioned by OFAC may seek administrative reconsideration under 31 C.F.R. section 501.807, request a licence and pursue available judicial review. State Department sanctions have a separate review process. OFAC launched its Reconsideration Portal on 29 June 2026, and its current petition guidance directs applicants to that portal. The regulation supplies the reconsideration procedure; the portal guidance describes the current submission route. Process existence does not prove speed or outcomes, so permanence and rarity claims require data (section 501.807 as republished in 2024; current OFAC petition guidance).

Doctrine and contested interpretation

Doctrine

Administrative review, due process, property, statutory construction and foreign-affairs deference govern disputes. Zevallos v Obama reviewed denial of a delisting request under the Kingpin Act and related due-process claims. Al Haramain addressed notice and Fourth Amendment questions involving a United States entity. Neither supplies a universal rule for all designees.

Contested interpretation

Humanitarian permissions remain programme-specific. The general licences announced in December 2022 following Resolution 2664 define activities, providers, exclusions and conditions. They do not remove designations, unblock all property or authorise every humanitarian transaction. Their present applicability must be checked under the relevant programme and current authorisation (2022 regulatory amendments; OFAC FAQs 1105-1108).

Current position at 21 October 2026

As at 21 October 2026, the Sanctions List Service remains the current publication source. A historical example illustrates why record changes need interpretation: on 27 July 2026 OFAC consolidated duplicate entries while expressly retaining sanctions on the associated persons and property (27 July notice). Aliases, duplicates, vessels, aircraft and changing data models make static counts unreliable. Live claims require retrieval date and programme authority.

See also

Office of Foreign Assets Control (United States) · OFAC 50 Percent Rule · Secondary sanctions · Compliance cascade · Asset freeze · International Emergency Economic Powers Act (1977) · Sectoral Sanctions Identifications (SSI) List · General licences · Financial statecraft

Sources

1. Office of Foreign Assets Control, Sanctions List Service, checked 21 October 2026.
2. Office of Foreign Assets Control, FAQ 91, updated 21 August 2024.
3. Office of Foreign Assets Control, FAQ 398 and FAQ 401, guidance on control, ownership and indirect ownership; FAQ 9, blocking and property, updated 21 August 2024; checked 21 October 2026.
4. Office of Foreign Assets Control, Archive of Changes to the SDN List, checked 18 October 2026.
5. Department of the Treasury, Alphabetical Listings: Specially Designated Nationals and Blocked Persons; Blocked Vessels; Persons Determined To Be the Government of Iran, final rule, 76 Fed. Reg. 38534, 30 June 2011, particularly pages 38534-38535.
6. Office of Foreign Assets Control, Reporting, Procedures and Penalties Regulations, interim final rule, 89 Fed. Reg. 40372, 10 May 2024, section 501.807 at page 40378; FAQ 897, updated 29 June 2026; and How to Request Removal from an OFAC Sanctions List, checked 21 October 2026.
7. Office of Foreign Assets Control, 'Launch of OFAC Reconsideration Portal', 29 June 2026.
8. Office of Foreign Assets Control, 'Sanctions List Removals; Sanctions List Updates', 27 July 2026.
9. Zevallos v Obama, 793 F.3d 106 (D.C. Cir. 2015), opinion.
10. Al Haramain Islamic Foundation, Inc. v United States Department of the Treasury, 686 F.3d 965 (9th Cir. 2012), amended opinion.
11. United States Department of the Treasury, 'Treasury Implements Historic Humanitarian Sanctions Exceptions', 20 December 2022.
12. Office of Foreign Assets Control, Additional Sanctions Lists and Sanctions Programs and Country Information, checked 21 October 2026.
13. United States Department of the Treasury, The Department of the Treasury's De-Risking Strategy, April 2023, pages 1-4.
14. Office of Foreign Assets Control, Addition of General Licenses to OFAC Sanctions Regulations for Certain Transactions of Nongovernmental Organizations and Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates for Medical Devices, final rule, 87 Fed. Reg. 78484, 21 December 2022, particularly section 594.520 at pages 78504-78505; FAQs 1105-1108, released 20 December 2022, checked 21 October 2026.