Specially Designated Nationals and Blocked Persons List

The Specially Designated Nationals and Blocked Persons List, or SDN List, is OFAC's live administrative publication identifying persons and property treated as blocked under programme-specific law. Listing communicates a blocking consequence but is not its universal legal source, does not identify every blocked person and differs from OFAC's non-blocking lists.

Legal character and authority

The list consolidates identifiers and programme tags from country and thematic programmes. Statutes, executive orders and regulations establish designation criteria, blocking, exemptions, licensing and enforcement. OFAC publishes and administers many entries; State makes some designations reflected in OFAC data.

An entry's programme tag, statute, order, regulation, notice and licences determine its effect. The list is a publication and data service, not independent blocking authority. Some programmes block governments, categories or ownership interests without naming every affected person.

Reach is programme-specific. Rules commonly block property in the United States or possessed or controlled by United States persons and prohibit covered dealings by them. Foreign-person and secondary-sanctions exposure must be established separately.

Blocking, ownership and list distinctions

Blocking immobilises property without transferring title. The 50 Percent Rule blocks an unlisted entity owned, directly or indirectly, 50 per cent or more in aggregate by one or more blocked persons. Control, office or ownership below 50 per cent does not automatically block it under that rule, although other prohibitions may apply.

Non-SDN lists can impose sectoral, menu-based, investment, correspondent-account or other restrictions rather than blocking. Listed SDNs, unlisted category members, 50 Percent Rule entities, non-SDN restricted persons and secondary-sanctions exposure are distinct.

Treasury removed list appendices from 31 C.F.R. chapter V in 2011 and adopted online publication. OFAC now delivers live data through its Sanctions List Service. The metadata date 1994 is a schema accommodation tied to OFAC's earliest continuous change archive, not the origin of SDN categories or predecessor lists.

Statecraft use and transmission

The list implements targeted measures involving states, officials, firms, armed groups, terrorism, proliferation, narcotics and cyber activity. Designation, publication, licensing and removal have a direct state nexus. Covered firms act as regulated intermediaries.

Foreign firms may react to secondary exposure, correspondent access, screening limits or risk appetite. This private cascade can amplify designation but is not an automatic legal consequence. Mandatory United States compliance, foreign exposure and over-compliance require separate evidence.

Designation criteria and notice establish official allegations, not compellent purpose, humanitarian effect or success.

Procedure and review

Listed persons may seek reconsideration under 31 C.F.R. section 501.807, request a licence and pursue available judicial review. OFAC launched its Reconsideration Portal on 29 June 2026. Process existence does not prove speed or outcomes, so permanence and rarity claims require data.

Doctrine and contested interpretation

Doctrine

Administrative review, due process, property, statutory construction and foreign-affairs deference govern disputes. Zevallos v Obama reviewed one designation and due-process claim. Al Haramain addressed notice and Fourth Amendment questions involving a United States entity. Neither supplies a universal rule for all designees.

Contested interpretation

Humanitarian permissions remain programme-specific. December 2022 general licences following Resolution 2664 define activities, providers, exclusions and conditions. They do not remove designations, unblock all property or authorise every humanitarian transaction.

Current position at 29 July 2026

The Sanctions List Service is the current publication source. OFAC changed the list on 27 July 2026, including deletion of duplicate records, which is not necessarily sanctions removal. Aliases, duplicates, vessels, aircraft and changing data models make static counts unreliable. Live claims require retrieval date and programme authority.

See also

Office of Foreign Assets Control (United States) · OFAC 50 Percent Rule · Secondary sanctions · Compliance cascade · Asset freeze · International Emergency Economic Powers Act (1977) · Sectoral Sanctions Identifications (SSI) List · General licences · Financial statecraft

Sources

1. Office of Foreign Assets Control, Sanctions List Service, checked 29 July 2026.
2. Office of Foreign Assets Control, FAQ 91, updated 21 August 2024.
3. Office of Foreign Assets Control, FAQs 398 to 402, guidance on entities owned by blocked persons.
4. Office of Foreign Assets Control, Archive of Changes to the SDN List, checked 29 July 2026.
5. Department of the Treasury, removal of appendices A and B to 31 C.F.R. chapter V and replacement with the online SDN List, 76 Fed. Reg. 38534, 30 June 2011, final rule.
6. 31 C.F.R. section 501.807, procedures governing delisting, and Office of Foreign Assets Control, FAQ 897, updated 29 June 2026.
7. Office of Foreign Assets Control, 'Launch of OFAC Reconsideration Portal', 29 June 2026.
8. Office of Foreign Assets Control, 'Sanctions List Removals; Sanctions List Updates', 27 July 2026.
9. Zevallos v Obama, 793 F.3d 106 (D.C. Cir. 2015), opinion.
10. Al Haramain Islamic Foundation, Inc. v United States Department of the Treasury, 686 F.3d 965 (9th Cir. 2012), amended opinion.
11. United States Department of the Treasury, 'Treasury Implements Historic Humanitarian Sanctions Exceptions', 20 December 2022.
12. Office of Foreign Assets Control, Additional Sanctions Lists, updated 27 July 2026.
13. Juan C. Zarate, Treasury's War: The Unleashing of a New Era of Financial Warfare (New York: PublicAffairs, 2013).