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Specially Designated Nationals (SDNs) and the SDN List
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18. What is an SDN?
As part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. Collectively, such individuals and companies are called "Specially Designated Nationals" or "SDNs." Their assets are blocked and U.S. persons are generally prohibited from dealing with them. [09-10-02]
19. How do I get a copy of the Specially Designated Nationals (SDN) List?
The best way to get the SDN list is from OFAC's website. The list is disseminated in a number of different formats, including XML and fixed field/delimited files that can be integrated into databases. [01-30-15]
20. How often is the Specially Designated Nationals (SDN) List updated?
The SDN list is frequently updated. There is no predetermined timetable, but rather names are added or removed as necessary and appropriate. [09-10-02]
21. How do I know what specific changes have been made to OFAC's Specially Designated Nationals List?
All changes for the current calendar year are cumulatively available in a .PDF file and in an ASCII version. Cumulative changes for prior years back to 1994 are also available in ASCII format by following this link. The same link will take you to a *.PDF version of the file for calendar years back to 2001. [11-16-07]
23. What do I do if I have a match to the Specially Designated Nationals (SDN) or one of OFAC's other sanctions lists?
If you have checked a name manually or by using software and find a match, you should do a little more research. Is it an exact name match, or very close? Is your customer located in the same general area as the SDN or another entry on one of OFAC's sanctions lists? If not, it may be a "false hit." If there are many similarities, contact OFAC's "hotline" at 1-800-540-6322 for verification. If your "hit" concerns an in-process wire transfer, you may prefer to e-mail your question to OFAC. Unless a transaction involves an exact match, it is recommended that you contact OFAC Compliance before actually blocking assets. [09-10-02]
466. How do I verify if a name was removed from one of OFAC’s sanctions lists?
For historical information about names that have been removed from OFAC’s Specially Designated Nationals List or one of OFAC’s other sanctions lists, please see our Archive of Changes page. Designation, removal, and update information is organized chronologically by list and by year. [04-21-2016]
56. What is the difference between the Specially Designated Nationals (SDN) List and the Commerce Department's List of Denied Parties? Why can't they be integrated into one list? What about OFAC's other sanctions lists?
SDNs are individuals and entities located throughout the world that are blocked pursuant to the various sanctions programs administered by OFAC. SDNs can be front companies, parastatal entities, or individuals determined to be owned or controlled by, or acting for or on behalf of, targeted countries or groups. They also can be specially identified individuals such as terrorists or narcotics traffickers. U.S. persons are prohibited from engaging in any transactions with SDNs and must block any property in their possession or under their control in which an SDN has an interest. SDNs are designated primarily under the statutory authority of the Trading With the Enemy Act, the International Emergency Economic Powers Act, the Anti-Terrorism and Effective Death Penalty Act and the Foreign Narcotics Kingpin Designation Act. OFAC also administers several other sanctions lists including the Foreign Sanctions Evaders (FSE) List and the Sectoral Sanctions Identifications (SSI) List. U.S. persons are not required to block the property of individuals and entities on these FSE and SSI lists (unless the targets are also on the SDN list), but other prohibitions and investment restrictions apply.
The Bureau of Industry and Security ("BIS") of the U.S. Department of Commerce maintains separate lists for the purposes of the programs that it administers (including the Denied Persons List and the Entity List). The Denied Persons List consists of individuals and companies that have been denied export and reexport privileges by BIS. The Entity List consists of foreign end users who pose an unacceptable risk of diverting U.S. exports and the technology they contain to alternate destinations for the development of weapons of mass destruction. Accordingly, U.S. exports to those entities may require a license. Authority for the Denied Persons List and the Entity List can be found in Title 15, Part 764, Supplement No. 2 and Title 15, Part 744, Supplement No.4 of the U.S. Code of Federal Regulations, respectively.
The foreign policy objectives and legal requirements of OFAC's lists are significantly different from those of the BIS lists. The unique goals of the OFAC and BIS programs preclude the creation of a combined OFAC and BIS list. [01-30-2015]
How to Search OFAC's Sanctions Lists
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On October 10, 2014, OFAC upgraded Sanctions List Search to incorporate additional sanctions lists. The improved search tool employs fuzzy logic on its name search field to look for potential matches on the Specially Designated Nationals (SDN) List and on its Consolidated Sanctions List. This consolidated list includes the Non-SDN, Palestinian Legislative Council List "NS-PLC List," the Part 561 List, the Non-SDN Iran Sanctions Act List "NS-ISA List," the Foreign Sanctions Evaders List "FSE List," the Sectoral Sanctions Identifications List "SSI List", and the List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599 "the 13599 List"). [01-16-2016]
82. Does OFAC have a web-based search engine for its sanctions lists?
Yes, OFAC does maintain its own web-based search service. It can be accessed at the following URL: https://sanctionssearch.ofac.treas.gov/. [10-10-2014]
246. How does Sanctions List Search work?
In addition to returning results that are exact matches (when the match threshold slider bar is set to 100%), Sanctions List Search can also provide a broader set of results using fuzzy logic. This logic uses character and string matching as well as phonetic matching. Only the name field of Sanctions List Search invokes fuzzy logic when the tool is run. The other fields on the tool use character matching logic. Please click here for more information on what a true sanctions list match is. [10-10-2014]
247. What does the Sanctions List Search Score mean?
The score field indicates the similarity between the name entered and resulting matches on one of OFAC's sanctions lists. It is calculated using two matching logic algorithms: one based upon phonetics, and a second based upon the similarity of the characters in the two strings. A score of 100 indicates an exact match, while lower scores indicate potential matches. [10-10-2014]
248. How do I use the Minimum Name Score field and score slider bar?
The minimum name score field limits the number of names returned by the search. A value of 100 will return only names that exactly match the characters entered into the name field. A value of 50 will return all names that are deemed to be 50% similar based upon the matching logic of the search tool. By lowering the match threshold the system will return a broader result set. [02-05-2013]
249. How is the Score calculated?
Sanctions List Search uses two matching logic algorithms, and two matching logic techniques to calculate the score. The two algorithms are Jaro-Winkler, a string difference algorithm, and Soundex, a phonetic algorithm. The first technique involves using the Jaro-Winkler algorithm to compare the entire name string entered against full name strings of entries on OFAC's sanctions lists. The second technique involves splitting the name string entered into multiple name parts (for example, John Doe would be split into two name parts). Each name part is then compared to name parts on all of OFAC's sanctions lists using the Jaro-Winkler and Soundex algorithms. The search calculates a score for each name part entered, and a composite score for all name parts entered. Sanctions List Search uses both techniques each time the search is run, and returns the higher of the two scores in the Score column. [10-10-2014]
250. Does OFAC recommend a specific match threshold score?
OFAC cannot make such a recommendation because each search has its own unique set of facts surrounding it. Users of Sanctions List Search must make their own match threshold determinations based upon their own internal risk assessments and established compliance practices. [06-09-2014]
251. What fields influence the score?
Only the name field influences the score. [02-05-2013]
252. What fields use fuzzy logic?
Only the name field uses the fuzzy searching logic. [02-05-2013]
253. When conducting a search using the ID field, does Sanctions List Search account for variations in non-alphanumeric characters?
Sanctions List Search’s ID field uses exact character matching to provide users with a result. In order to receive the broadest number of results, users should conduct ID field searches both with and without any non-alphanumeric characters. [06-09-2014]
287. Who may use Sanctions List Search? Can we configure our automated system to utilize Sanctions List Search on a continual basis?
Sanctions List Search is a free tool provided by OFAC to assist the public in complying with sanctions programs. It is intended to be used by individual users that are looking for potential matches on OFAC's sanctions lists. It should not be utilized by automated systems that are configured to continually run searches through the tool. For a copy of files that can be easily interpreted by automated systems and software programs, please see the list of XML, CSV, PIP, DEL, and FF files on the SDN and Consolidated Sanctions List pages. [10-10-2014]
369. Does Sanctions List Search look for potential matches on all of the various sanctions lists that OFAC has published on its website?
Sanctions List Search will look for and return potential matches from the SDN and Consolidated Sanctions Lists. The user can look under the List column to see which list(s) a potential match is on. Please see the Consolidated List page for more detailed information on what is included in the Consolidated List. [10-10-2014]
467. Does the Sanctions List Search tool show historic information? For example, does it show names that have been removed from one of OFAC's sanctions lists?
OFAC's Sanctions List Search is updated frequently and always contains the latest versions of OFAC's sanctions lists. Like OFAC's other list-related publications, Sanctions List Search does not contain historical information. Names that have been removed from OFAC's Specially Designated Nationals or Consolidated Lists are not included in Sanctions List Search. Likewise, targets that have been updated only appear with their most up to date entry information. For historical information about a target on one of OFAC's sanctions lists, please see our archive page. [04-21-2016]
Information on List File Formats and Downloads
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80. Does OFAC provide its SDN List in a spreadsheet format?
OFAC publishes the SDN data in a comma separated values format (CSV). This format is recognized by Excel and other spreadsheet programs and can be imported into spreadsheet format by simply opening the file in your default spreadsheet application. [06-14-07]
422. How do I get a copy of one or more of OFAC’s other sanctions lists (in addition to the Specially Designated Nationals list)?
OFAC maintains other sanctions lists in addition to its Specially Designated Nationals (SDN) list. The names on these lists may also appear on the SDN list when such targets have a blocking provision associated with them. However, when the treatment of sanctions targets is unique and stops short of the blocking treatment, these names will appear on the one of OFAC's non-SDN lists. Links to the human-readable versions of these lists can be found here. Data versions of these lists are now being disseminated in a single, consolidated data file (known as the Consolidated Sanctions List). These data files can be found here. [02-02-15]
81. What is the delimiter in OFAC's delimited files?
The delimiter varies based upon the file type. Files that end in .DEL have an @ (at) symbol as the delimiter. Files that end in .CSV have a comma delimiter. Files that end in .FF have a fixed width delimiter. Files that end in .PIP use the | (pipe) symbol as a delimiter. [06-14-07]
84. Does OFAC maintain its files on an FTP server or in locations other than on its website?
Yes. OFAC maintains many of its sanctions list files on an FTP server.
This server can be accessed at: ftp://ofacftp.treas.gov.
The server will accept an anonymous login. OFAC's data is stored in the directories listed below.
/fac_sdn - SDN human-readable lists, legacy zip archive (XML and delimited files), and the advanced zip archive (advanced XML file)
/fac_bro - country and program brochures
/fac_delim - SDN data files (advanced XML file, legacy XML file, legacy delimited files) in un archived format
/ssi_list - All Sectoral Sanctions List files
/fse_list - All Foreign Sanctions Evaders List files
/ns_plc - All Non-SDN Palestinian Legislative Council Lists files
/consolidated_list - All Consolidated Non-SDN List data files [10-10-14]
85. Is there a version of the SDN data file archive that works with UNIX, Linux or other command line operating systems?
Yes. The standard zip archive should work with most UNIX and Linux systems and is available on OFAC's website at https://www.treasury.gov/ofac/downloads/sdall.zip and its FTP site at ftp://ofacftp.treas.gov in the folder /fac_sdn. [08-06-14]
87. Your FTP site has gone offline. Who should I contact to remedy this problem?
The FTP site at ofacftp.treas.gov is run by OFAC. Contact OFAC's support hotline at 1-800-540-6322 for technical support. [08-06-14]
88. I am a developer looking to design an automated process that will download OFAC's Specially Designated Nationals (SDN) list and other sanctions lists without human intervention. How can I do this given that changes to the sanctions lists can be sporadic?
OFAC cannot give specific advice on how to design an automated system for downloading its sanctions list data. Many institutions solve this problem by setting up a scheduled download of the SDN List and other sanctions lists. These firms conduct their own risk assessments and decide how often they need to download the lists in order to comply with U.S. law. Institutions should be aware that OFAC is updating its sanctions lists at an ever increasing pace. If an institution has set up a periodic download schedule, the institution should occasionally reevaluate that schedule to ensure that it remains an effective risk mitigation technique. [01-30-15]
89. I am a database administrator at a financial institution and am responsible for keeping my company's Specially Designated Nationals (SDN) data current. Is the SDN list comprehensive or do I need to download some kind of supplement to the list every time there is an update?
The SDN list is comprehensive. Database administrators can overwrite any old data in their systems with the latest versions of the list's data files, thus ensuring that their database is current. [09-10-02]
90. Do you offer a Specially Designated Nationals (SDN) changes file or "delta file" in a data format? Do you offer delta files for OFAC's other sanctions lists?
No. OFAC records changes to the SDN and other sanctions lists in human-readable form in the recent actions section of its website. An archive of changes files found on this page. Database administrators interested in refreshing their databases with new SDN and other sanctions list data should use the comprehensive data files available on OFAC's website and completely refresh the list. [10-08-13]
22. Does OFAC maintain or can it create a country-by-country list of SDNs?
OFAC has long maintained such a list. The file is available on OFAC's SDN Page under the link "SDN List Sorted by Country." The file is also contained within the SDALL.ZIP archive and is called ctrylst.txt. It is important to understand that many SDN individuals and entities may operate in countries other than those in which they are based. The relevant regulations prohibit transactions with and/or block the property of SDNs wherever they are located. [04-14-14]
105. OFAC says it has updated its SDN list, but when I download the appropriate SDN files from the OFAC website, they appear to be out-of-date. Where can I get the latest SDN information?
OFAC has rigorous quality control procedures in place to ensure that all SDN data are current and accurate when they are released. All of the SDN information is downloaded and checked by OFAC personnel using the same interface that any member of the public might employ. A number of local issues can impact a user’s ability to download current information; many of these issues are associated with caching done by a user’s browser or by the firewall/security systems that protect a specific enterprise. OFAC can only offer technical support when it comes to OFAC provided data and OFAC managed systems (like the OFAC website or OFAC FTP servers). If you continue to have difficulty downloading the latest SDN information, OFAC recommends that you contact your internal IS/IT support and request their assistance in resolving a caching issue. Users having specific problems opening the PDF/Adobe Acrobat version of the SDN list may also review the information available here. [03-20-2008]
Advanced XML Sanctions List Standard
For additional information regarding OFAC's Advanced XML file formats, please see the following page.
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122. What are weak aliases (AKAs)?
A "weak AKA" is a term for a relatively broad or generic alias that may generate a large volume of false hits when such names are run through a computer-based screening system. OFAC includes these AKAs because, based on information available to it, the sanctions targets refer to themselves, or are referred to, by these names. As a result, these AKAs may be useful for identification purposes, particularly in confirming a possible "hit" or "match" triggered by other identifier information. Realizing, however, the large number of false hits that these names may generate, OFAC qualitatively distinguishes them from other AKAs by designating them as weak. OFAC has instituted procedures that attempt to make this qualitative review of aliases as objective as possible. Before issuing this updated guidance, OFAC conducted a review of all aliases on the Specially Designated Nationals (SDN) list. Each SDN alias was run through a computer program that evaluated the potential of an alias to produce false positives in an automated screening environment. Names were evaluated using the following criteria:
- Character length (shorter strings were assumed to be less effective in a screening environment than longer strings);
- The presence of numbers in an alias (digits 0-9);
- The presence of common words that are generally considered to constitute a nickname (example: Ahmed the Tall);
- References in the alias to geographic locations (example: Ahmed the Sudanese);
- The presence of very common prefixes in a name where the prefix was one of only two strings in a name (example: Mr. Smith).
Aliases that met one or more of the above criteria were flagged for human review. OFAC subject matter experts then reviewed each of the automated recommendations and made final decisions on the flagging of each alias.
OFAC intends to use these procedures to evaluate all new aliases added to its sanctions lists. [01-18-11]
123. Where can I find weak aliases (AKAs)?
Weak AKAs appear differently depending on which file format of the sanctions list is being utilized.
In the TXT and PDF versions of the Specially Designated Nationals (SDN) or other sanctions lists, weak AKAs are encapsulated in double-quotes within the AKA listing:
ALLANE, Hacene (a.k.a. ABDELHAY, al-Sheikh; a.k.a. AHCENE, Cheib; a.k.a. "ABU AL-FOUTOUH"; a.k.a. "BOULAHIA"; a.k.a. "HASSAN THE OLD"); DOB 17 Jan 1941; POB El Menea, Algeria (individual) [SDGT]
In the DEL, FF, PIP, and CSV file formats, weak AKAs are listed in the Remarks field (found at the end of the record) of the primary name file. In these formats, weak AKAs are bracketed by quotation marks. Please see the data specification documents for more information on the SDN and Consolidated lists.
8219 @"ALLANE, Hacene"@"individual"@"SDGT"@-0- @-0- @-0- @-0- @-0- @-0-@-0- @"DOB 17 Jan 1941; POB El Menea, Algeria; a.k.a. 'ABU AL-FOUTOUH'; a.k.a. 'BOULAHIA'; a.k.a. 'HASSAN THE OLD'."
In the legacy XML version of OFAC's sanctions lists, there is a Type element for each AKA. The Type can either be 'weak' or 'strong' (see the XML SDN and Consolidated List Schemas (XSD files) at: https://www.treasury.gov/resource-center/sanctions/SDN-List/Documents/sdn.xsd and https://www.treasury.gov/ofac/downloads/consolidated/consolidated.xsd for more information).
In the advanced XML list standard, alias quality is represented as a Boolean attribute of the alias element. This attribute, "LowQuality" can be flagged as either "true" or "false." If the LowQuality attribute is false then the alias is strong. If the LowQuality attribute is true then the alias is weak.
For more information on the advanced XML standard, please visit OFAC’s SDN data formats page at https://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/sdn_data.aspx. [01-30-15]
124. Am I required to screen for weak aliases (AKAs)?
OFAC’s regulations do not explicitly require any specific screening regime. Financial institutions and others must make screening choices based on their circumstances and compliance approach. As a general matter, though, OFAC does not expect that persons will screen for weak AKAs, but expects that such AKAs may be used to help determine whether a “hit” arising from other information is accurate. [01-18-11]
125. Will I be penalized for processing an unauthorized transaction involving a weak alias (AKA)?
A person who processes an unauthorized transaction involving a sanctions list entry has violated U.S. law and may be subject to an enforcement action. Generally speaking, however, if (i) the only sanctions reference in the transaction is a weak AKA, (ii) the person involved in the processing had no other reason to know that the transaction involved an entry on one of OFAC's sanctions lists or was otherwise in violation of U.S. law, and (iii) the person maintains a rigorous risk-based compliance program, OFAC will not issue a civil penalty against an individual or entity for processing such a transaction. [01-18-11]