Beyond OFAC: Additional sanctions lists US businesses should know

OFAC is not the only game in town

For US businesses, OFAC compliance is the top priority. The SDN List and other OFAC lists are the primary sanctions lists you are legally required to screen against. But they are not the only sanctions lists that matter. Depending on your business, your risk profile, and your partners, you may also want to screen against international sanctions lists and US export control lists.

BIS and State Department export-control lists

The Bureau of Industry and Security (BIS), part of the US Department of Commerce, maintains export control lists that restrict dealings with certain foreign parties:

• Entity List: Companies and individuals subject to specific export license requirements. Exporting certain items to parties on the Entity List without a license is prohibited.
• Denied Persons List (DPL): Individuals and entities that have been denied export privileges entirely.
• Unverified List: Foreign parties whose bona fides BIS could not confirm in an end-use check. Exports to them need extra due diligence and a statement from the buyer.
• Military End-User List: Foreign military end users that need a license for certain items.

The State Department keeps two more: the ITAR Debarred List of parties barred from defense trade, and its nonproliferation sanctions on foreign parties under the Arms Export Control Act and related statutes.

If your business exports goods, technology, or software, screening against BIS lists is essential. Even if you do not think of yourself as an exporter, you might be surprised. Software downloads, cloud services, and technology transfers can all qualify as exports under US law.

EU Financial Sanctions Facility (EU FSF)

The European Union maintains its own sanctions list, known as the EU Consolidated List, accessible through the EU Financial Sanctions Facility. This list includes individuals and entities sanctioned by the EU under various programs.

Why should a US business care about EU sanctions? Several reasons:

• If you do business in or with EU countries, EU sanctions may apply to those transactions.
• EU and US sanctions often overlap, but not always. Screening against both lists provides better coverage.
• Your European customers, partners, or correspondent banks may require you to screen against EU lists.

The EU FSF currently contains roughly 30,000 entries, making it one of the largest sanctions lists in the world.

UN Consolidated Sanctions List

The United Nations Security Council maintains a consolidated list of individuals and entities subject to UN sanctions. These sanctions are implemented through Security Council resolutions and are binding on all UN member states.

In practice, most UN-sanctioned parties are also listed on the OFAC SDN List, because the US implements UN sanctions through OFAC. However, screening against the UN list directly provides an additional layer of coverage and demonstrates a thorough compliance program.

The UN Consolidated List is relatively small, with about 1,000 entries, but it carries significant weight because of its international authority.

UK Sanctions List

Since Brexit the UK has run its own sanctions regime, and UK and EU designations have drifted apart. The Foreign, Commonwealth & Development Office publishes them in the UK Sanctions List, which became the only official UK list on 28 January 2026, when the separate list kept by the Treasury's Office of Financial Sanctions Implementation (OFSI) closed. OFSI still enforces UK financial sanctions.

US businesses that work with UK counterparties or process transactions through UK financial institutions should consider screening against the UK Sanctions List. It runs to several thousand entries and is updated regularly.

Other lists worth knowing

Depending on your industry, you may also want to be aware of the Canada SEMA List, Swiss SECO Sanctions, and Australia DFAT Sanctions. Most US businesses will not need to screen against all of these, but being aware of them helps you make informed decisions about the scope of your screening program.

When should US businesses screen beyond OFAC?

Consider screening against additional lists if:

• You conduct international transactions, especially with European, UK, or Canadian counterparties.
• You export goods, technology, or software.
• Your bank or business partners require it.
• You want to demonstrate a thorough compliance program to regulators, auditors, or customers.
• Your customers include foreign nationals or multinational companies.

OFACScreen and international lists

OFACScreen includes the major international sanctions lists and the US export-control lists in addition to the OFAC SDN List. We screen 14 lists in every search: OFAC SDN, OFAC Non-SDN, EU Financial Sanctions, UN Security Council, UK Sanctions List, Canada SEMA, Swiss SECO, Australia DFAT, BIS Denied Persons, BIS Entity List, BIS Unverified List, BIS Military End-User, ITAR Debarred and State Nonproliferation. UAE Local Terrorist List, Japan MOF, Israel NBCTF crypto wallets, France Registre des gels, Poland MSWiA, Mexico SAT 69-B, FBI Most Wanted, FinCEN Special Measures and UFLPA Entity List are optional. You choose when to include them. That gives you broad coverage with a single screening tool, without needing to manage multiple data sources yourself.