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 Entity List and Denied Persons List

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. The two most relevant lists are:

• 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.

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 OFSI Consolidated List

The UK's Office of Financial Sanctions Implementation (OFSI) maintains the UK sanctions list. Since Brexit, UK and EU sanctions have diverged somewhat, so the UK list is now distinct from the EU list.

US businesses that work with UK counterparties or process transactions through UK financial institutions should consider screening against the OFSI list. The list contains roughly 5,000 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 several major international sanctions lists in addition to the OFAC SDN List. We currently screen against the OFAC SDN List, OFAC Non-SDN Lists, EU Financial Sanctions Facility, UN Consolidated List, and UK OFSI Consolidated List. This gives you broad coverage with a single screening tool, without needing to manage multiple data sources yourself.