Legal authority

Sectoral Sanctions Identifications (SSI) List

The Sectoral Sanctions Identifications List, or SSI List, identifies persons subject to one or more directive-based restrictions under Executive Order 13662 (2014). It is a non-SDN list. An SSI entry does not by itself block all property of the listed person. The applicable directive, issue date, ownership and any overlapping designation determine the legal consequence.

Directive structure

Directive 1 restricts specified new debt and new equity of identified persons in Russia's financial sector. Directive 2 restricts specified new debt of identified persons in the energy sector. Directive 3 restricts specified new debt of identified persons in the defence and related-materiel sector. For instruments issued on or after 28 November 2017, the principal maturity limits are longer than 14 days under Directive 1, longer than 60 days under Directive 2 and longer than 30 days under Directive 3. Earlier issue periods retain the thresholds then applicable.

Directive 4 is not a debt restriction. It prohibits specified provision, exportation or re-exportation of goods, services other than financial services, or technology supporting certain deepwater, Arctic offshore or shale exploration or production projects. The project location, initiation date, resource potential and participation of a directive-covered person matter. The 2017 amendment added specified projects outside Russia where a covered person has the stated ownership or voting interest.

List, ownership and transaction boundaries

The list record states which directive or directives apply to each person. OFAC's 50 Percent Rule extends the same restrictions to an entity owned, directly or indirectly, 50 per cent or more in aggregate by one or more persons subject to the directive. A minority interest or control without that ownership threshold does not automatically create SSI status, although other sanctions may apply.

Transactions prohibited only by an SSI directive are generally rejected, not blocked. A person can separately be designated on the Specially Designated Nationals and Blocked Persons List. If blocking authority applies, United States persons must block covered property even though the person also has an SSI record.

Debt, equity, extended payment terms, derivatives, ordinary goods and services, and project support require separate analysis. The existence of a correspondent account is not automatically prohibited by Directives 1 to 3, but the bank must not process a transaction that constitutes prohibited new debt, equity or another restricted dealing.

Strategic significance and current position

The SSI design sought to increase funding and technology costs for selected Russian sectors without fully excluding major firms from the financial system. It offered calibrated pressure in 2014. Later blocking and directive measures imposed after 2022 may be more restrictive, but they do not erase the SSI framework.

OFAC recorded the SSI List as last updated on 27 July 2026 when checked on 30 July 2026. Transaction analysis must still use the current list record, directive text, relevant issue date, ownership evidence and licences.

See also

Executive Order 13662 (2014) · Sectoral sanctions · Specially Designated Nationals and Blocked Persons List · debt sanctions · oilfield services and technology controls · Asset freeze

Sources

  1. Office of Foreign Assets Control, Additional Sanctions Lists: Sectoral Sanctions Identifications List, checked 30 July 2026.
  2. Office of Foreign Assets Control, Ukraine-/Russia-related sanctions, Directives 1 to 4 under Executive Order 13662, checked 30 July 2026.
  3. Office of Foreign Assets Control, FAQ 370, debt and blocking distinction.
  4. Office of Foreign Assets Control, FAQ 373, extension of directive restrictions to entities owned 50 per cent or more by covered persons.

Recommended citation

Cite this entry

Tennant, James J., ed. 'Sectoral Sanctions Identifications (SSI) List.' The Encyclopedia of Economic Statecraft, version 2.0, last reviewed 30 July 2026. https://jamesjtennant.com/entries/sectoral-sanctions-identifications-ssi-list/.

Suggest an edit