Frequently Asked Questions

For purposes of E.O. 13959, as amended, activity by U.S. persons related to the following services are considered permissible, to the extent that such support services are not provided to U.S. persons in connection with prohibited purchases or sales: clearing, execution, settlement, custody,… Read more

No.  If a person is listed on OFAC’s Non-SDN Menu-Based Sanctions List (NS-MBS List)  as subject to only a combination of the sanctions described in section 235(a)(1-8) and (10-11) of CAATSA , as implemented by Executive Order (E.O.) 13849 , these non-blocking sanctions do not apply to an entity… Read more

With respect to a person on the NS-MBS List subject to section 235(a)(3) of CAATSA , as implemented by section 1(a)(i) of Executive Order (E.O.) 13849 , U.S. financial institutions are prohibited from making loans or providing credits to the identified person totaling more than $10,000,000 in any… Read more

Yes.  Market intermediaries, including market makers, and other participants may engage in ancillary or intermediary activities that are necessary to effect divestiture during the relevant wind-down periods or that are not otherwise prohibited under E.O. 13959, as amended.  Purchases or sales by U.… Read more

Consistent with FAQ 865 , which clarifies that market intermediaries and other participants may engage in ancillary or intermediary activities that are necessary to effect divestiture during the relevant wind-down periods or that are not otherwise prohibited under E.O. 13959, as amended,… Read more

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

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 List… Read more

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. …

The SDN list is frequently updated. There is no predetermined timetable, but rather names are added or removed as necessary and appropriate. …

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 hit… Read more