OFAC Sanctions List — Practitioner's Guide

The Specially Designated Nationals and Blocked Persons (SDN) List is OFAC's master list of blocked individuals and entities. Transactions with SDNs are prohibited regardless of which country they're in or what country program applies.

Search: sanctionssearch.ofac.treas.gov — free, public, updated in real time.

What to search: Names of all parties: counterparties, beneficial owners, intermediaries, vessel names, aircraft tail numbers. Fuzzy matching matters — "Ivan Petrov" and "I. Petrov" can be the same person.

The 50% Rule: Entities owned 50% or more by SDN-listed persons are automatically blocked, even if the entity itself doesn't appear on the SDN list. This rule applies to aggregated ownership — two blocked persons each owning 30% adds up to 60% and triggers the rule.

This is where most sophisticated violations occur. The entity clears the SDN search. The beneficial owner doesn't.

Russia — Sectoral Program

Russia is NOT a comprehensive sanctions program. Restrictions apply to specific sectors (energy, defense, financial services) and specific designated parties — not all Russian nationals or entities.

The complexity is in the sector definitions. Energy sector: oil, gas, and related services are largely restricted. But some energy-related services have general licenses. Practitioners must check the current program page and applicable general licenses, not just the SDN list.

Key practical point: a Russian national not on the SDN list and not in a restricted sector may transact. Many practitioners over-block on Russia by treating it as comprehensive. Check the sector definitions before refusing a transaction.

Iran — Comprehensive Program

Virtually all transactions with Iran, the Iranian government, and Iranian financial institutions are prohibited absent a specific license.

Narrow exceptions exist for food, medicine, and informational materials. These require careful documentation. The comprehensive nature of Iran sanctions means the default answer is no — practitioners should look for a general license that covers their specific transaction, not assume one exists.

Cuba — Comprehensive with Significant General Licenses

Cuba sanctions are comprehensive but with broader general license carve-outs than Iran. General licenses cover travel, remittances, and certain transactions with Cuban nationals living outside Cuba.

Practitioners must check which general license applies to their specific transaction — the carve-outs are real but require knowing the license scope. Transactions with the Cuban government and Communist Party remain restricted regardless of general licenses.

Venezuela — Broad Blocking Program (EO 13884)

Venezuela is often described as a sectoral sanctions program, but Executive Order 13884 (August 5, 2019) effected a broad blocking order on all property and interests in property of the Government of Venezuela. This is effectively a comprehensive blocking program as to the Venezuelan government — not merely a sectoral restriction.

Practitioners must distinguish between: (1) transactions involving the Venezuelan government or government-controlled entities (broadly blocked under EO 13884), and (2) transactions with private Venezuelan nationals and entities not on the SDN list (may proceed absent SDN hit or other program restriction).

Common error: treating Venezuela as fully comprehensive for all counterparties, or conversely treating it as merely sectoral like the early-stage program. The post-EO 13884 framework is a hybrid — comprehensive as to the government, limited as to private parties. Check whether the specific counterparty has government ties before concluding a transaction is permissible.

If any layer returns a positive match — stop.

1. Halt the transaction. Don't process, don't wire, don't close.
2. Preserve the assets. If funds are already received from a potentially blocked source, OFAC regulations may require you to freeze them and file a report.
3. Document everything. Timestamp when you found the hit, what you searched, what you found.
4. Escalate to compliance counsel. Identifying the hit is the screening function. Deciding what to do with it requires sanctions expertise.

False positives are common. Common names without jurisdiction context generate many false positives. The screening step is to catch and investigate, not to automatically refuse every match. The key question: Is this actually the same person or entity?

Note on commercial screening tools: Large-volume transactional work typically uses commercial screening software (LexisNexis World Compliance, Dow Jones Watchlist, Refinitiv). These are not substitutes for understanding the framework — they are tools for applying it at scale.

This page covers: identifying whether you have an OFAC problem and what kind.

You need specialized counsel when:

• You got a hit and need to determine if it's a true match and what your obligations are
• You received funds you believe may be from a blocked source — mandatory reporting obligations apply
• You want to apply for a specific license — OFAC's licensing process has strategic and legal dimensions
• You're considering voluntary self-disclosure — OFAC's mitigation framework rewards early disclosure, but how you self-disclose matters
• You're in a merger or acquisition — target-side OFAC liability transfers on closing; you need pre-closing diligence
• You're in energy, defense, or financial services — sector-specific programs are more complex and change more frequently

OFAC sanctions compliance is a specialist field. The identification step — which this page covers — is something every practitioner touching international work needs to understand. The resolution step is not DIY.