Guide to OFAC’s “Specially Designated Nationals List”
The Office of Foreign Assets Control (OFAC), part of the US Treasury Department, administers the economic sanctions imposed by the government against hostile targets. These sanctions are important foreign policy tools, used to advance national security objectives. One category of targets includes countries, such as Cuba, North Korea, Sudan, Iran and Myanmar. A second category of targets is comprised of groups – such as narcotics traffickers or terrorists – and individuals.
OFAC maintains a list of target countries, as well as a “Specially Designated Nationals List (SDN). The SDN list, which is constantly updated, identifies every entity and individual with whom US persons may not transact business. At any given time there are thousands of entries on the list. If a prohibited transaction occurs with a targeted country, entity or individual, a fine or other penalty may be imposed on the offending company.
Every company must determine how it can best comply with the OFAC rules. At the very least, each business needs to understand its customers and the likelihood of performing transactions with prohibited individuals or entities. It also needs to train its employees about OFAC and the rules regarding the Country and SDN lists. Depending on the circumstances, a company may decide to identify a compliance officer and to institute a regular practice of checking the SDN list, particularly in the case of new customers. For many businesses, checking the SDN list before engaging with a new customer, and on a periodic basis thereafter, is already an established part of their anti-money laundering program.
The SDN list is available on JVC’s website here.