Frequently Asked Questions

63 … If an existing policyholder or a named beneficiary is blocked by OFAC and the provision of insurance services is not authorized or exempt, then the insurer is required to block the policy or relevant portion of the policy (e.g., the individual's policy under a group health insurance plan),… Read more

64 … If an insurer has knowledge that a person covered under a group policy, for example a worker's compensation policy, is blocked pursuant to OFAC sanctions, the insurer’s coverage of that person pursuant to the worker's compensation policy is blocked. If a claim is made under the blocked portion… Read more

65 … OFAC may impose civil penalties for sanctions violations based on strict liability, meaning that a person subject to U.S. jurisdiction may be held civilly liable even if such person did not have knowledge that it was engaging in a transaction that was prohibited under sanctions laws and… Read more

102 … The best and most reliable approach for issuing policies with global risk coverage without violating U.S. sanctions law is to include a clause ensuring there is no coverage for risks that violate U.S. sanctions law. The exact wording of such clauses may vary depending on the type of policy (e… Read more

103 … OFAC recognizes that U.S. insurers and reinsurers often compete in international markets where non-U.S. insurers are willing and able to issue global insurance policies without an exclusion that applies to U.S. sanctions, or where such clauses may be prohibited under local law. In cases where… Read more

18 … As part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not… Read more

21 … All changes for the current calendar year are cumulatively available in the SDN List PDF file . The entire list may also be browsed using OFAC's Sanctions List Search Tool ​. Cumulative changes for prior years back to 1994 are also available in ASCII format on the Archive of Changes to the SDN… Read more

19 … The best way to get the SDN list is from OFAC's website . The list is disseminated in a number of different formats, including XML and fixed field/delimited files that can be integrated into databases. … How do I get a copy of the Specially Designated Nationals (SDN) …

20 … The SDN list is frequently updated. There is no predetermined timetable, but rather names are added or removed as necessary and appropriate. … How often is the Specially Designated Nationals (SDN) List …

23 … If you have checked a name manually or by using software and find a match, you should do a little more research. Is it an exact name match, or very close? Is your customer located in the same general area as the SDN or another entry on one of OFAC's sanctions lists? If not, it may be a "false… Read more