Ask any compliance officer what keeps them awake at night, and chances are it is the moment a client's name suddenly shows up on "the OFAC list." But there is no single list. The U.S. Office of Foreign Assets Control maintains a family of sanctions lists, each with different legal consequences. Mixing them up can lead to blocked funds, frozen shipments, or, in the worst case, civil penalties on a strict liability basis. Companies of every size, therefore, need a working grasp of SDN, SSI, and FSE lists, how they differ, and when a hit requires you to stop a transaction or simply file a report.
Overview of OFAC Lists
SDN List – the whole block.
The SDN List names individuals, companies, vessels, and even crypto wallets whose assets fall under a blanket freeze. Any transaction by a U.S. person—or by anyone touching the U.S. financial system—is broadly prohibited. A Russian bank, an Iranian shipping line, or a ransomware operator can all end up here if Washington wants to cut them off completely.
SSI List – sectoral speed limit.
The Sectoral Sanctions Identifications (SSI) List is narrower. It focuses on considerable Russian energy, defense, and finance firms, limiting how long U.S. persons may extend new credit or equity (often 14 or 30 days). Ordinary trade in goods is still allowed; long-term financing is shut down.
FSE List – the sanctions detour.
The Foreign Sanctions Evaders (FSE) List targets those who help Iran or Syria bypass restrictions, such as middlemen arranging ship-to-ship oil transfers. U.S. persons must refuse any business with an FSE, but there is no automatic asset freeze unless the same party is also on the SDN List.
NS-ISA List – Iran's energy firewall.
Under the Iran Sanctions Act, the NS-ISA List names firms that invest heavily in Iran's petroleum sector or supply it with key technology. The main consequence is a ban on U.S. loans or credit above a modest dollar threshold—enough to make large projects financially awkward without imposing a whole block.
NS-MBS List – menu-based penalties.
"Menu-based sanctions" give policymakers options. Each NS-MBS designation spells out which of a dozen possible measures apply—import bans, procurement blocks, financing limits, or visa restrictions. Think of it as à la carte pressure, tailored case by case.
NS-PLC List – reject, don't block.
Finally, the NS-PLC List identifies Hamas-affiliated members of the Palestinian Legislative Council. U.S. banks must reject—not block—any transaction they try to route through the U.S. system. Funds bounce back to the sender; they do not sit frozen on a suspense account.
Taken together, these lists form a layered toolkit: a blunt hammer (SDN), a sectoral speed limit (SSI), a detour sign (FSE), and a few more surgical instruments (NS-ISA, NS-MBS, NS-PLC). Recognizing which tool you’re looking at is the first step toward the right compliance response.
OFAC updates these lists without a set timetable; additions can appear on any business day.
For a full introduction to all OFAC lists, read our comprehensive OFAC sanctions overview.
SDN List Explained
Purpose and Enforcement
The SDN list names individuals, entities, vessels, and aircraft whose property and interests in property are blocked. U.S. persons (banks, insurers, exporters, fintech firms, even independent contractors) are generally prohibited from engaging in any transactions with an SDN.
Examples
🔹Prominent Russian financial institutions such as Sberbank and VTB
🔹Drug traffickers named pursuant to the Kingpin Act
🔹Cybersecurity threat actors associated with North Korean hacking operations
Legal Implications
🔹Full asset freeze in U.S. jurisdiction; no “wind-down” unless OFAC issues a specific license.
🔹50 Percent Rule: entities owned 50 percent or more, directly or indirectly, by one or more SDNs are themselves blocked, even if not named.
Blocking must be reported to OFAC within 10 business days.
SSI List (Sectoral Sanctions Identifications)
What Is It?
The SSI list targets companies operating in designated sectors of the Russian economy—currently energy, defense, and finance—under Executive Order 13662.
Industries Affected
🔹Oil & gas majors
🔹State-owned defense contractors
🔹Large Russian banks and holding companies
Restrictions
Instead of an asset freeze, SSI listings impose narrow financing bans. For example, under Directive 3, U.S. persons can’t make loans longer than 14 days or buy new shares in the listed companies.
Foreign Sanctions Evaders - FSE List
Who Gets Listed?
Foreign individuals and entities that help Iran or Syria skirt U.S. sanctions—for instance, by routing oil payments through front companies—can be named under Executive Order 13608.
Practical Effect
🔹U.S. persons must exit any transaction involving an FSE.
🔹Asset freeze is not automatic unless the party is also included in the SDN list; the prohibition is on engaging in transactions involving goods, services, or technology.
Example
The FSE list was used in 2022 to add a Turkish national who organized ship-to-ship transfers of Iranian crude to cut off access to U.S. dollar clearing, although his assets were not frozen.
Other OFAC Lists: NS-ISA, NS-MBS, NS-PLC
NS-ISA (Iran Sanctions Act). Target companies pouring major money or technology into Iran’s energy industry. Penalty: U.S. banks must pull back new loans or credit once exposure tops roughly USD 10 million in a year.
NS-MBS (Menu-Based Sanctions). Lets OFAC pick from a roster of penalties—import bans, procurement blocks, debt limits—tailored case-by-case. The list spells out exactly which measures hit each name.
NS-PLC (Palestinian Legislative Council). Flags Hamas-linked legislators. U.S. banks must reject—not freeze—any payments they try to route through the American financial system.
Comparison: SDN vs SSI vs FSE vs Others
The SDN list is a blunt instrument—once a name appears, every U.S.-linked transaction must halt, and assets freeze on impact. SSI, FSE, and the niche lists (NS-ISA, NS-MBS, NS-PLC) slice the rules more finely, imposing debt caps, dealings bans, or simple “reject” orders instead of full blocking; mixing them up can mean either paralyzing a perfectly legal payment or waving through a prohibited one.
Use-Case Scenarios & Risk Check: What to Do When a Name Pops Up
Name is on the SDN List—stop everything. Freeze any funds in your control, cancel pending shipments, and file an OFAC blocking report within ten business days. Only a specific OFAC licence can restart the relationship.
Name is on the SSI List only—focus on financing limits. Daily trade in goods may continue, but do not extend new loans beyond the directive’s maturity cap (14 or 30 days, depending on the sector). Record your rationale and monitor for directive changes.
Name is on the FSE List—reject the deal, don’t block assets. U.S. persons must refuse to provide goods or services, yet no asset freeze applies unless the same party is also an SDN. Keep evidence of the rejection in your KYC file.
Dual-listed (SDN + SSI or SDN + FSE)—the toughest rule wins. If any SDN tag is present, treat the person as fully blocked. The stricter sanction always takes precedence.
Listed under NS-ISA or NS-MBS—read the fine print.Check the specific measures attached: some prohibit new credit, others bar U.S. government contracting or import licences. Tailor your response to the listed penalties.
NS-PLC match—reject, then bounce. For Hamas-linked legislators, U.S. banks must reject the transaction and return the funds. No blocking report is needed, but note the rejection in your audit trail.
How to Monitor All Lists Efficiently
Update Cadence
🔹SDN — “frequently” with no set schedule
🔹SSI — amendments are published whenever a new Directive change is issued.
🔹FSE — sporadic; last update December 2022.
🔹NS-MBS & NS-PLC — updates announced on OFAC’s Recent Actions feed.
Screening Best Practices
- Batch nightly, screen real-time triggers. Even low-risk businesses should run at least daily delta files across all OFAC lists.
- Use consolidated data feeds. OFAC’s Sanctions List Service offers machine-readable CSV/XML files combining non-SDN lists for unified ingestion.
- Automate 50 Percent Rule checks. Ownership analytics prevent missed SDN hits.
- Document false-positive clearing. Regulators scrutinise your rationale when names are similar.
Unified Screening Software
Look for tools that can:
🔹Ingest SDN plus every non-SDN list in one API call.
🔹Flag which legal effect applies (block, reject, debt limit).
🔹Store audit trails to demonstrate how you applied OFAC vs other sanctions lists from the EU or UN.
Want to know how to screen these lists in real-time? Check our OFAC screening guide for implementation tips.
Conclusion
The shorthand below turns dozens of Federal Register pages into a single snapshot:
Key takeaway: The phrase “OFAC list” masks a diverse toolkit. Knowing whether a name is on the blocked persons list, the SSI list, OFAC, or the FSE list dictates how you respond, how quickly, and with what paperwork. Keep your screening engines current, log every decision, and the next surprise update should be a manageable compliance exercise rather than a headline-making enforcement action.
Staying on top of these moving parts means more than checking the SDN file daily. The directive numbers change, ownership structures shift, and new names can arrive with no advance warning. Using a provider that consolidates all OFAC lists and applies the proper rules automatically reduces both workload and error rate.
If you would rather not build that infrastructure yourself, KYCAID offers an out-of-the-box feed that screens against every OFAC list (and others) in a single pass. No hype; it simply saves time and lets your team focus on the judgment calls that still need a human eye.
