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56. What is the difference between the Specially Designated Nationals (SDN) List and the Commerce Department's List of Denied Parties? Why can't they be integrated into one list? What about OFAC's other sanctions lists?


SDNs are individuals and entities located throughout the world that are blocked pursuant to the various sanctions programs administered by OFAC. SDNs can be front companies, parastatal entities, or individuals determined to be owned or controlled by, or acting for or on behalf of, targeted countries or groups. They also can be specially identified individuals such as terrorists or narcotics traffickers. U.S. persons are prohibited from engaging in any transactions with SDNs and must block any property in their possession or under their control in which an SDN has an interest. SDNs are designated primarily under the statutory authority of the Trading With the Enemy Act, the International Emergency Economic Powers Act, the Anti-Terrorism and Effective Death Penalty Act and the Foreign Narcotics Kingpin Designation Act. OFAC also administers several other sanctions lists including the Foreign Sanctions Evaders (FSE) List and the Sectoral Sanctions Identifications (SSI) List. U.S. persons are not required to block the property of individuals and entities on these FSE and SSI lists (unless the targets are also on the SDN list), but other prohibitions and investment restrictions apply.

The Bureau of Industry and Security ("BIS") of the U.S. Department of Commerce maintains separate lists for the purposes of the programs that it administers (including the Denied Persons List and the Entity List). The Denied Persons List consists of individuals and companies that have been denied export and reexport privileges by BIS. The Entity List consists of foreign end users who pose an unacceptable risk of diverting U.S. exports and the technology they contain to alternate destinations for the development of weapons of mass destruction. Accordingly, U.S. exports to those entities may require a license. Authority for the Denied Persons List and the Entity List can be found in Title 15, Part 764, Supplement No. 2 and Title 15, Part 744, Supplement No.4 of the U.S. Code of Federal Regulations, respectively.

The foreign policy objectives and legal requirements of OFAC's lists are significantly different from those of the BIS lists. The unique goals of the OFAC and BIS programs preclude the creation of a combined OFAC and BIS list.

Date Released
January 30, 2015