Updated

GL-S-03

Glossary · Due Diligence and compliance

SDN List - the main US sanctions list that banks worldwide check

SDN List — the OFAC (US) list of specially designated nationals: people and companies with whom transactions are prohibited for US persons and those under US jurisdiction.

Full glossary
OFACwho keeps the list
banon transactions
hardglobal effect

01 / In 30 seconds

The short answer

What it is
The SDN List — OFAC’s list of specially designated nationals (USA)
Who is on it
People and companies under US sanctions
What it means
US citizens and persons under US jurisdiction are prohibited from dealing with them
Consequences
A hard stop for accounts, passports, business
How to use it
Check that you are not on the list during due diligence

02 / In plain words

What SDN List means

The SDN List (Specially Designated Nationals and Blocked Persons List) is the key sanctions list kept by OFAC, the US Treasury’s Office of Foreign Assets Control. It includes people, companies and organisations subject to US sanctions: US citizens and residents, and persons under US jurisdiction, are prohibited from doing business with them, and their assets in that jurisdiction are blocked.

Although it is an American list, its influence is global. Because of the role of the dollar and the US financial system, most international banks and organisations around the world check against the SDN List and avoid dealing with those on it — otherwise they risk falling under secondary sanctions themselves. That is why being on this list is one of the most serious obstacles in international finance.

In the context of investment migration, being on the SDN List is a hard deal-breaker: no serious bank will open an account, and no reputable programme will issue a passport to a person under US sanctions. Sanctions screening in due diligence always includes a check against this list. As with other sanctions, false name matches are possible and need to be cleared properly. We check this in advance.

A case from practice

During a check, a client’s name matched a person on the SDN List — a namesake from another country. Without an explanation no bank would have dealt with them. We identify the match in advance and prepare documents proving that it is a different person — and the check goes through cleanly.

Where the SDN List matters

  • Sanctions screening in due diligence
  • Opening bank accounts
  • International payments and business
  • Checking clients and partners
  • Sanctions risk assessment
  • Clearing false name matches

03 / What it covers

What matters about the SDN List

01

What it is

  • The OFAC list (USA)
  • Specially designated nationals
  • Under US sanctions
02

Ban

  • Transactions prohibited
  • Assets blocked
  • For persons under US jurisdiction
03

Effect

  • Global influence
  • Because of the role of the dollar
  • Banks avoid them
04

Keep in mind

  • A hard deal-breaker
  • Checked in DD
  • False matches are possible

04 / How it works

How to take the list into account

Step 1

A preliminary SDN check

We look for your name on the list before applying.

Step 2

Sanctions screening

Checks against the SDN and other lists.

Step 3

Reviewing matches

Date of birth, nationality, documents.

Step 4

Clearing false positives

We prove the match is not you.

Step 5

A clean result

The bank and the programme see a clean result.

05 / Key facts

What you need to know

01What it is

The OFAC list

Kept by the US Treasury's Office of Foreign Assets Control. It lists people, companies and organisations under US sanctions.

02What it means

A ban on dealings

Persons under US jurisdiction may not deal with those listed, and their assets are blocked.

03Reach

Global

Because of the dollar, banks worldwide avoid listed persons so as not to face secondary sanctions.

04For an applicant

A hard stop

No account and no passport from a serious programme. A false name match is cleared with documents.

Common mistakes

Thinking the list does not matter outside the US

Remember that banks around the world check it.

Not checking yourself in advance

Run an SDN check before applying.

Ignoring a match with a namesake

Prepare documents showing it is a different person.

06 / Expert advice

Klara Rihter

How to prepare in advance

Before a serious check it makes sense to confirm that you are not on the SDN List by checking yourself against the OFAC database in advance. If a false name match with a sanctioned person arises, documents are prepared proving that it is not you. Real sanctions status cannot be concealed, and a false match needs to be cleared. We carry out such a preliminary check and the explanations.

What we do for you. We check you in advance against the SDN List and other sanctions databases to avoid surprises in due diligence. In the event of a false name match, we prepare documents that settle the question. That way you pass one of the strictest sanctions filters cleanly, and the process is not held up by a namesake.

Klara RihterBanking compliance and source of funds specialist

07 / Questions

Frequently asked questions

The Specially Designated Nationals List — OFAC’s (the US Treasury’s) main sanctions list: people and companies under US sanctions, transactions with whom are prohibited for persons under US jurisdiction.

Yes, its influence is global. Because of the role of the dollar, most international banks check against the SDN List and avoid dealing with those on it, fearing secondary sanctions.

One of the most serious barriers in finance: assets blocked in the US jurisdiction and banks and programmes around the world refusing to deal with the person.

Yes, it is a hard deal-breaker: a reputable programme will not issue a passport to a person under US sanctions, and a bank will not open an account for them.

Yes, false name matches with a namesake on the list are possible. They must be cleared properly with documents — otherwise the process will be held up.

By checking against the OFAC database before applying. We carry out a preliminary check and, in the event of a false match, prepare explanatory documents.

Author: Klara Rihter

Reviewed by: Dmitry Nagy

Sources: OFAC — Specially Designated Nationals List

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Anna Kovalevskaya, lead lawyer at BRIDGES GLOBAL
Anna KovalevskayaLead lawyer, citizenship and residency, 12 years of practice