OFAC Sanctions List

OFAC administers over 35 sanctions programs, each with its own legal authority, target population, and compliance obligations. The SDN list is the most visible, but country-based sanctions programs — Cuba, Iran, North Korea, Syria — impose blanket prohibitions that extend beyond listed individuals to entire jurisdictions. The Specially Designated Nationals list is updated without advance notice, sometimes multiple times in a single week. In Q1 2025, OFAC added over 400 entries across its various programs. US persons — including foreign subsidiaries of US companies — are prohibited from transacting with SDNs regardless of where the transaction occurs. We cover program-by-program obligations, list update frequency, and the documentation standard OFAC expects when a voluntary self-disclosure is necessary.