Understanding OFAC Sanctions Programs: SDN, Sectoral, and Country-Based

More Than Just the SDN List

When people think of OFAC, they usually think of the SDN List. That is the most well-known sanctions list, but it is not the only one. OFAC administers more than 30 different sanctions programs, each with its own rules, prohibitions, and scope. Understanding these programs matters because different types of transactions can trigger different rules.

The SDN List

The Specially Designated Nationals and Blocked Persons List is the cornerstone of OFAC enforcement. It contains individuals, companies, and other entities with whom US persons cannot do business. If someone is on the SDN List, you must block their assets and refuse to process any transactions involving them.

The SDN List covers designations from across all of OFAC's sanctions programs. Someone might appear on the SDN List because they are linked to terrorism, narcotics trafficking, weapons proliferation, or a sanctioned government. The list currently contains roughly 18,000 to 19,000 primary entries, plus thousands of aliases.

Sectoral Sanctions (the SSI List)

Sectoral sanctions are a newer tool that OFAC introduced primarily in response to Russia's actions in Ukraine. Unlike SDN designations, which block all transactions with a listed party, sectoral sanctions prohibit specific types of transactions with the listed parties.

For example, the Sectoral Sanctions Identifications (SSI) List includes Russian companies in the financial services, energy, and defense sectors. US persons are prohibited from certain activities with these companies, such as providing new financing above certain maturity thresholds, but other types of business may still be permitted.

The key difference: SDN designations are a full block. Sectoral sanctions are targeted restrictions on specific types of dealings. This makes compliance more nuanced because you need to understand not just who is on the list, but what specific activities are prohibited.

Country-Based Sanctions Programs

OFAC maintains sanctions programs targeting specific countries and regions. As of 2025, these include programs covering:

• Iran: One of the most extensive programs. Broad prohibitions on trade, investment, and financial transactions.
• North Korea: Similarly broad, with very limited exceptions.
• Cuba: Restrictions on trade and travel, though some exemptions exist.
• Syria: Broad trade and financial restrictions.
• Russia: A complex and evolving program with multiple components.
• Crimea, Donetsk, and Luhansk regions: Separate restrictions tied to the Russia/Ukraine conflict.

Country-based programs can prohibit broad categories of transactions, not just dealings with specific listed parties. This means you could violate sanctions even if the other party is not on any list, simply because the transaction involves a sanctioned country.

The Non-SDN Lists

OFAC also maintains several other lists beyond the SDN List:

• Consolidated Non-SDN List: Combines entries from the SSI List, the Foreign Sanctions Evaders List, the Non-SDN Palestinian Legislative Council List, and others.
• Non-SDN Menu-Based Sanctions List (NS-MBS): Parties subject to specific, limited sanctions rather than full blocking.

Each of these lists has different implications. Not all of them require full blocking; some only prohibit certain activities.

Why This Matters for Your Business

If you are only screening against the SDN List, you may be missing important risks. A solid compliance program should screen against the full range of OFAC lists and should be configured to account for the different types of restrictions each program imposes.

OFACScreen screens against the SDN List, the Non-SDN Consolidated List, and several other major sanctions lists. We keep our data current so you are always screening against the latest information.