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North America, Latam

OFAC’s SDN List: Scope, Key Sanctions Programs, and Delisting Considerations

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) maintains the Specially Designated Nationals and Blocked Persons List (SDN List), a key tool of U.S. sanctions policy that imposes strict restrictions on designated individuals and entities, including asset blocking and prohibitions on transactions with U.S. persons. Exposure extends beyond listed parties, as those who engage with SDNs—directly or indirectly—may face enforcement actions or secondary sanctions, potentially limiting access to the U.S. financial system. With recent sanctions targeting geopolitical and transnational threats such as Russia, Iran and affiliated groups, and Latin American drug trafficking organizations, these developments highlight the broad reach of U.S. sanctions and the critical need for robust compliance measures.

Authors:

Louie A. Ayash

ayash@clm.com

 

Matthew D. Dunn

Partner

mdunn@clm.com

 

Darius R. Alam

Counsel

dalam@clm.com

 

Bryan J. Hall

Partner

Hall@clm.com