SDN List vs. Non-SDN Lists: Understanding the Difference
Ask most people about OFAC screening and they think of the SDN list. But OFAC maintains multiple sanctions lists, and other US and international agencies publish their own. Screening only against the SDN list leaves real gaps in your compliance program.
The SDN List
The Specially Designated Nationals and Blocked Persons List is the big one. It contains over 12,000 entries as of 2025: individuals, companies, vessels, and aircraft. The rules are straightforward: block their assets and don't do business with them. Period.
The Consolidated Non-SDN List
This is where things get more nuanced. The Non-SDN list rolls up several program-specific lists:
- Sectoral Sanctions (SSI) - Targets specific sectors of sanctioned economies. Restrictions are narrower than the SDN list (e.g., limits on debt and equity rather than a full block).
- Foreign Sanctions Evaders (FSE) - Entities helping sanctioned parties dodge sanctions.
- Non-SDN Menu-Based Sanctions (NS-MBS) - A newer category with variable restrictions depending on the sanctions program.
The restrictions for Non-SDN entries vary by program. Some require full blocking, others restrict specific types of transactions. You need to understand which program an entry falls under to know what's prohibited.
Beyond OFAC
Other lists that matter:
- BIS Denied Persons List - The Bureau of Industry and Security tracks people denied US export privileges. Doing business with them can violate export controls.
- UN Security Council - Binding on all UN member states.
- EU, UK, Canada, Switzerland - Each maintains its own sanctions regime. If you do any cross-border business, these lists matter.
The Practical Takeaway
Screen against all the lists that apply to your business. For most US companies, that means at minimum the SDN list and the Consolidated Non-SDN list. If you have international operations or customers, add the relevant international lists. Running a single search across multiple lists takes no more time than checking one.