What is the SDN List? Sanctions & Blocked Funds
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What is the SDN (Specially Designated Nationals) list?

The SDN (Specially Designated Nationals and Blocked Persons List) is a list of individuals and entities controlled by or belonging to target countries under OFAC sanctions, as well as terrorists, drug traffickers, and other persons posing a threat to U.S. national security. Individuals on the SDN list have their assets frozen, and U.S. citizens are prohibited from conducting any business transactions with them. The SDN list is published by the Office of Foreign Assets Control (OFAC) and is regularly updated. Companies that are 50% or more owned by individuals on the SDN list are also automatically considered blocked.

What does “SDN” actually stand for, and why “Blocked Persons”?

SDN stands for Specially Designated National. The full name of the list — Specially Designated Nationals and Blocked Persons List — reflects two overlapping categories. “Specially Designated Nationals” originally referred to individuals and entities acting on behalf of a sanctioned government. “Blocked Persons” is a broader category that includes parties blocked for other reasons — narcotics trafficking, terrorism, weapons proliferation, or cyber activity — regardless of any connection to a sanctioned country’s government. In practice, OFAC and the industry use “SDN” as shorthand for the entire combined list.

What is included on the SDN list?

The list is not limited to individuals. Entries include:.

  • Individuals — named persons, identified with aliases, dates and places of birth, and known addresses where available;
  • Companies and organizations — including shell entities and holding structures used to obscure ownership;
  • Vessels — ships identified by name and IMO number, often tied to sanctions evasion in the oil or shipping sectors;
  • Aircraft — identified by tail number, used in similar evasion schemes.

Each entry is tagged with the specific sanctions program under which it was designated (for example, Iran, North Korea, narcotics trafficking, or cyber-related sanctions), which determines the exact scope of the prohibition.

Who do blocked funds from individuals on the SDN list belong to?

Blocking is not confiscation. Funds or property blocked because of a connection to an SDN remain the legal property of that individual or entity — ownership does not transfer to the U.S. government or to the institution holding the funds. The bank or company holding the assets is simply prohibited from allowing any transaction, transfer, or use of those funds without OFAC authorization. Blocked funds are typically placed in an interest-bearing account and held indefinitely until the block is lifted — either through a specific license, or, where the designation itself is challenged, through removal from the list.

Is the SDN list the only OFAC sanctions list?

No. The SDN list is OFAC’s primary and most well-known list, but OFAC also maintains several narrower lists — such as the Sectoral Sanctions Identifications (SSI) List and the Non-SDN Menu-Based Sanctions List — that impose more limited restrictions than a full SDN designation. A name match against OFAC data does not automatically mean an SDN hit; the specific list and program determine what is actually prohibited.

Is the SDN List a criminal wanted list?

  • No. The SDN List is a sanctions designation list, not a wanted list. Being named on it doesn’t mean the person has been charged or convicted of a crime — it means OFAC has determined they meet the criteria for a specific sanctions program, which triggers an asset freeze rather than a criminal warrant.

Is the SDN List maintained by the FBI?

  • No. The SDN List is maintained by OFAC, a division of the U.S. Department of the Treasury — not the FBI or any law enforcement agency. The FBI investigates crimes; OFAC administers economic sanctions. The two operate under entirely different legal authorities.

Is the SDN List the same as the INTERPOL list?

  • No. The SDN List and INTERPOL Notices serve different purposes. The SDN List is a U.S. Treasury sanctions designation triggering an asset freeze. An INTERPOL Notice is a law-enforcement alert requesting a person’s location or arrest pending extradition. A name can appear on one without appearing on the other.

Which of the following best describes the SDN List?

  • The SDN List is best described as a list of individuals and entities associated with U.S. sanctions — not a criminal wanted list, and not limited to drug traffickers. It covers a broad range of designation categories, from sanctioned-government affiliates to terrorists, narcotics traffickers, and weapons proliferators.

What is included in the SDN List?

  • As covered above, entries include individuals, companies, vessels, and aircraft, each tagged with the specific sanctions program under which they were designated. See “What is included on the SDN list?” for the full breakdown.

Who is placed on the SDN List?

  • OFAC places individuals and entities on the list when they’re found to act on behalf of a sanctioned government, or when they’re independently designated for narcotics trafficking, terrorism, weapons proliferation, or cyber-related activity — regardless of any government connection.

What is the SDN List? (a) A list of the OFAC sanctions (b) A list of criminals wanted by the U.S. government (c) A list of individuals and entities associated with U.S. sanctions (d) A list of drug traffickers

  • The correct answer is (c) — a list of individuals and entities associated with U.S. sanctions. It is not a general roster of OFAC sanctions programs (a), not a criminal wanted list (b), and not limited only to drug traffickers (d), even though drug traffickers can appear on it under a specific program.
Ahmed Abdelaziem Mahmoud
Legal Adviser — INTERPOL & International Criminal Law

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