22. Does OFAC maintain or can it create a country-by-country list of Specially Designated Nationals (SDNs)?

OFAC has long maintained such a list. The file is available on OFAC's SDN Page under the link "SDN List Sorted by Country."  It is important to understand that many SDN individuals and entities may operate in countries other than those in which they are based. The relevant regulations prohibit transactions with and/or block the property of SDNs wherever they are located