OFAC Sanctions Search and SDN Screening: Current Sources and Workflow

What the OFAC SDN List is

The US Treasury's Office of Foreign Assets Control administers economic and trade sanctions programs. Its Specially Designated Nationals and Blocked Persons List—the SDN List—contains designated individuals, entities, groups, vessels, and aircraft. OFAC states that their property and interests in property are blocked under applicable authorities.

The SDN List is not OFAC's only list. The agency also publishes consolidated non-SDN lists whose restrictions vary. Start by identifying the exact list and sanctions program rather than treating every OFAC result as legally identical.

Use the official OFAC search—and understand what it returns

OFAC's Sanctions List Service provides current downloadable data, customized datasets, archives, and the official Sanctions List Search application. OFAC says its name search uses fuzzy logic to look for potential matches across the SDN and consolidated non-SDN lists.

Fuzzy matching is a discovery step. Confirm the legal name, aliases, entity type, address, country, dates, identification numbers, vessel or aircraft details, program tags, and other evidence before treating a candidate as the listed person. The score does not make that decision.

The 50 Percent Rule makes name-only screening incomplete

For a focused explanation of aggregation, indirect ownership, control, and evidence gaps, see the OFAC 50 Percent Rule guide.

OFAC's current FAQs state that entities owned 50 percent or more in the aggregate—directly or indirectly—by one or more blocked persons are themselves considered blocked. Ownership stakes from multiple blocked persons are aggregated, including when the owners are blocked under different programs.

OFAC separately explains that control without 50 percent aggregate ownership does not automatically block an entity under the 50 Percent Rule. That does not make the relationship risk-free: a blocked person may still be involved in the transaction, another sanctions authority may apply, or OFAC may separately designate the controlled entity.

Embargo can surface approved source-linked ownership evidence where available. It does not claim complete ownership coverage, infer missing stakes as facts, or make the legal determination for the customer.

A defensible OFAC screening workflow

1. Collect identity evidence. Use the legal name, aliases, local script, address, country, entity type, registration identifiers, and relevant vessel or aircraft identifiers.
2. Search current official data. Check OFAC's Sanctions List Service and record the list or program involved.
3. Resolve the candidate. Compare multiple identifiers; do not confirm a match from name similarity alone.
4. Review ownership. Identify direct and indirect blocked owners, aggregate relevant stakes, and document unresolved gaps.
5. Assess the actual transaction. Review every party, role, location, currency or financial route, relevant program, and possible authorization with qualified counsel where needed.
6. Preserve the disposition. Record the evidence, source version, timestamp, reviewer, rationale, escalation, and final decision.

Why OFAC and BIS checks remain separate

OFAC sanctions and BIS export controls use different authorities and can produce different restrictions. A counterparty can appear in both systems, and a result in one does not answer the other. BIS analysis also requires item, destination, end-use, end-user, and licensing review under the EAR; OFAC analysis depends on the applicable sanctions authority, parties, property interests, conduct, and authorization.

Use the BIS Entity List guidefor the Commerce-side workflow. Embargo's screening surface can return supported evidence from both systems without collapsing their legal effects into one conclusion.

When to re-screen

OFAC's compliance framework describes sanctions as dynamic and says effective controls should be able to adjust to list updates, program changes, regulations, guidance, and general licenses. A risk-based policy may include screening at onboarding, before a transaction, when material counterparty details change, and after a relevant OFAC publication.

Embargo processes supported registry publications and re-screens saved counterparties after publication. Collection, validation, publication, evaluation, and notification each take time; a polling interval is not a guaranteed alert time.

What to preserve for the audit record

• the submitted identity and identifiers available at the time;
• the official OFAC list, program, and source evidence reviewed;
• the data or publication version and screening timestamp;
• the match reason, uncertainty, and ownership evidence considered;
• the reviewer, disposition, rationale, and escalation path; and
• the transaction-specific legal or licensing analysis maintained in the appropriate compliance system.

Embargo screening certificates and exports preserve supported product evidence. They document an Embargo outcome; they do not certify that a transaction is legally authorised.

Official OFAC sources

• OFAC Sanctions List Service, official lists, downloads, and search
• OFAC Sanctions List Search tool and fuzzy-match description
• OFAC FAQs on entities owned by blocked persons
• Current OFAC sanctions-list updates
• OFAC compliance, enforcement, and civil-penalty resources

Frequently asked questions