3rd May 2018
Specially Designated Nationals And Blocked Persons List
What is theList?
In order to carry out its duties, the Office of Foreign Assets Control (OFAC) produces the Specially Designated Nationals and Blocked Persons list – also known as the OFAC SDN list.
The OFAC SDN list represents an essential tool in the fight against money laundering and terrorist financing in the United States and around the world. It forms part of the US Treasury’s Selective Sanctions policy in which specific individuals and organizations involved in certain criminal activities are penalized, as opposed to the more comprehensive approach of sanctioning entire nations.
What is a Blocked Persons and Specially Designated Nationals (SDN) List?
OFAC provides a search engine for the SDN list. Users may input certain parameters, including searches by country or specific sanction, in order to narrow their results.
Names returned by a search are accompanied by codes which indicate the reason why a person or organization has been included on the list: “BPI-PA”, for example, indicates that entry has been “blocked pending investigation” under the Patriot Act.
To deal with the use of aliases, search results are also accompanied by a score which indicates similarity to an inputted name. A score of ‘100’ indicates an exact match, while lower scores indicate only a potential match.
Where businesses have high volumes of clients and transactions it can be highly inefficient to individually search each potential customer or party to a relationship manually. This is magnified when considering beneficial owners and senior management of entities which may also need screening. Using an efficient screening technology can minimize the effort required while providing additional context around potential matches to deliver more accurate results and fewer false positives.
While there is no scheduled timetable, the OFAC SDN list is updated regularly. Updates to the list reflect the status of current and pending OFAC investigations, and users may look through archived changes, dating back to 1994.
The unpredictable and frequent changes to the SDN list mean businesses should look for a screening provider which maintains up to date, relevant, accurate data.
OFAC may remove names from the SDN list depending on the results of investigations, or for consistent behavior in accordance with the law. Alternatively, individuals and organizations on the list may petition OFAC for removal. In these situations, OFAC will conduct a rigorous review, and announce any changes on its ‘recent actions’ pages. All historical changes may be viewed on archived versions of the list.