OFAC SDN list

The OFAC SDN list (Specially Designated Nationals and Blocked Persons List) is the US Treasury Office of Foreign Assets Control's list of individuals, companies, vessels and other parties designated under US sanctions programs. OFAC FAQ 18 summarises the effect: "Their assets are blocked and U.S. persons are generally prohibited from dealing with them."

Why it matters in KYB review

For a US bank or fintech, onboarding a blocked person is a potential sanctions violation. SDN screening is therefore a gate in every business onboarding flow: the entity, its beneficial owners, its control person and, depending on policy, its directors and key counterparties.

Three facts shape how the check works in practice:

• The list moves. FAQ 20: "The SDN list is frequently updated. There is no predetermined timetable." Screening must use a current copy, and existing customers need rescreening when the list changes.
• The SDN list is not every OFAC list. OFAC maintains non-SDN lists with different consequences. FAQ 56 says US persons are not required to block property of parties only on the FSE and SSI lists, but "other prohibitions and investment restrictions apply."
• A company can be blocked without being listed. Under the 50 Percent Rule, an entity owned 50% or more in aggregate by blocked persons is blocked even though its name does not appear.

What an analyst checks

When screening returns a potential match, OFAC's guidance on assessing name matches says to "compare all of the details in the OFAC listing with the information available to you," including full name, aliases, nationality, passport numbers, date of birth, addresses and business registration numbers.

• Program tags and listing details on the SDN entry.
• Identifiers in the case: date of birth, nationality, registration number, address.
• Weak aliases, which OFAC flags separately and which generate many false hits.
• Ownership of the entity, to catch 50 Percent Rule exposure a name screen misses.
• Decision record: why the hit was cleared or escalated, with the fields compared.

If there is an exact match or a close match with multiple similarities, OFAC's guidance says to follow your sanctions compliance procedures.

Common pitfalls

• Clearing a hit because the first name differs, when the SDN entry lists that name as an alias.
• Screening only the applicant, not owners and controllers.
• Fuzzy-match thresholds so loose that analysts clear hundreds of hits by habit (see false positive).
• No record of the comparison, which leaves an auditor unable to tell a reviewed clearance from a rubber stamp.

Related terms

OFAC 50 Percent Rule, false positive (screening), alert escalation, ultimate beneficial owner.

Sweat AI is an AI-native BPO for banks and fintechs, working onboarding and fraud queues 24/7. Our analysts work screening hits overnight and at weekends, compare every identifier in the case against the listing, and record why each hit was cleared or escalated. Confirmed and unresolved matches go to your team. See 24/7 onboarding review.