Sectoral Sanctions Identifications (SSI) List

The Sectoral Sanctions Identifications List, or SSI List, identifies persons subject to one or more directive-based restrictions under Executive Order 13662 (2014). It is a non-SDN list. An SSI entry does not by itself block all property of the listed person. The applicable directive, issue date, ownership and any overlapping designation determine the legal consequence.

Directive structure

Directive 1 restricts specified new debt and new equity of identified persons in Russia's financial sector. Directive 2 restricts specified new debt of identified persons in the energy sector. Directive 3 restricts specified new debt of identified persons in the defence and related-materiel sector. For instruments issued on or after 28 November 2017, prohibited new debt includes maturities longer than 14 days under Directive 1 and longer than 60 days under Directive 2. Directive 3 has used a longer-than-30-day threshold since 12 September 2014. Earlier issue periods retain their applicable thresholds, subject to rules on changes of terms and rollovers. OFAC FAQ 371.

Directive 4 restricts goods, technology and services other than financial services for specified deepwater, Arctic offshore or shale oil exploration or production projects. Its first limb covers projects with oil potential in Russia or maritime areas claimed by Russia and extending from its territory, involving a directive-covered person or its property interests. Its second limb covers oil-potential projects in any location initiated on or after 29 January 2018 where covered persons hold at least 33 per cent ownership or a majority of voting interests. OFAC aggregates covered interests for those project tests. The 33 per cent project threshold is distinct from the 50 per cent rule that determines whether an entity is itself subject to the directive. Directive 4; OFAC FAQ 537 and FAQ 538.

List, ownership and transaction boundaries

The list record states which directive or directives apply to each person. OFAC's 50 Percent Rule extends the same restrictions to an entity owned, directly or indirectly, 50 per cent or more in aggregate by one or more persons subject to the directive. An ownership interest below that aggregate threshold or control alone does not automatically subject the entity to the directive, although other sanctions and Directive 4's separate project tests may apply. OFAC FAQ 373.

Transactions prohibited only by an SSI directive are generally rejected, not blocked. A person can separately be designated on the Specially Designated Nationals and Blocked Persons List. If blocking authority applies, United States persons must block covered property even though the person also has an SSI record.

Debt, equity, extended payment terms, derivatives, ordinary goods and services, and project support require separate analysis. The existence of a correspondent account is not automatically prohibited by Directives 1 to 3, but a transaction can still be prohibited under those directives or another sanctions authority. Payment terms can create prohibited new debt even where the underlying service is not itself prohibited. OFAC FAQ 371; OFAC enforcement release, 1 June 2026.

Strategic significance and current position

Treasury described the 2014 measures as restricting access to financing and technology while limiting wider economic disruption. Their selective transaction restrictions provided calibrated pressure without automatically imposing a comprehensive asset block. Later blocking and directive measures imposed from 2022 can impose additional restrictions on the same persons; the SSI framework continues alongside them. Treasury, 12 September 2014; Secretary Lew, 12 September 2014; OFAC FAQ 967.

When checked on 14 October 2026, OFAC's Additional Sanctions Lists page recorded the SSI List as last updated on 14 September 2026. This is the source page's list-update date, not an effective date for every listed person's restrictions. Transaction analysis must still use the current list record, directive text, relevant issue date, ownership evidence and licences.

See also

Executive Order 13662 (2014) · Sectoral sanctions · Specially Designated Nationals and Blocked Persons List · debt sanctions · oilfield services and technology controls · Asset freeze

Sources

1. United States Department of the Treasury, Office of Foreign Assets Control, Additional Sanctions Lists: Sectoral Sanctions Identifications List, list-update date 14 September 2026 (accessed 14 October 2026).
2. Office of Foreign Assets Control, Ukraine-/Russia-related Sanctions, current programme and directive index (accessed 14 October 2026).
3. Office of Foreign Assets Control, Directive 1 as amended under Executive Order 13662, 29 September 2017.
4. Office of Foreign Assets Control, Directive 2 as amended under Executive Order 13662, 29 September 2017.
5. Office of Foreign Assets Control, Directive 3 under Executive Order 13662, 12 September 2014.
6. Office of Foreign Assets Control, Directive 4 as amended under Executive Order 13662, 31 October 2017.
7. Office of Foreign Assets Control, FAQ 370, debt tenors and non-blocking restrictions, 28 November 2017; FAQ 371, debt, equity and correspondent accounts, updated 24 February 2022 (accessed 14 October 2026).
8. Office of Foreign Assets Control, FAQ 373, entity ownership; FAQ 537, project versus entity ownership; and FAQ 538, project aggregation, all 31 October 2017 (accessed 14 October 2026).
9. United States Department of the Treasury, Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589, subpart B, especially sections 589.201 to 589.205, eCFR text current through 8 October 2026 (accessed 14 October 2026).
10. Office of Foreign Assets Control, FTI Consulting, Inc., a Global Business Advisory Firm, Settles with OFAC for $1,050,000 Related to Apparent Violations of Dealing in Prohibited Debt of Sanctioned Russian Bank, enforcement release, 1 June 2026.
11. United States Department of the Treasury, Announcement of Expanded Treasury Sanctions within the Russian Financial Services, Energy and Defense or Related Materiel Sectors, 12 September 2014.
12. Jacob J. Lew, United States Secretary of the Treasury, Statement on Additional Sanctions within Russia's Financial Services, Defense or Related Materiel, and Energy Services Sectors, 12 September 2014.
13. Office of Foreign Assets Control, FAQ 967, Russia-related correspondent-account restrictions and overlapping authorities, updated 11 June 2026 (accessed 14 October 2026).