INTERNATIONAL TRADE LAW
U.S. Sanctions Lists: A Screening Guide
U.S. sanctions lists are government registries of people, companies, vessels, and aircraft that U.S. persons generally may not do business with — and screening your counterparties against them is the core of sanctions and export compliance. Multiple agencies publish multiple lists, each with its own legal effect. Knowing which list a name appears on tells you what you can and cannot do.
Why screening matters
Sanctions liability is generally strict — OFAC can penalize a U.S. business for dealing with a blocked party even if the business did not know the party was listed. Civil penalties are steep, and willful violations can be criminal. A documented, risk-based screening program is both the practical defense and the chief mitigating factor if something slips through. Because the lists change constantly, screening is not a one-time check at onboarding; it is repeated before transactions and re-run when lists update.
The OFAC lists (Treasury)
OFAC publishes the most important sanctions lists. They fall into two buckets:
- The SDN List — Specially Designated Nationals and Blocked Persons. This is the headline list. Anyone on it has their U.S. assets blocked, and U.S. persons are broadly prohibited from any dealings with them. It also covers vessels and aircraft.
- The Consolidated (non-SDN) Sanctions List — a master file of OFAC’s more limited programs, where the prohibitions are narrower than a full block. It includes the Sectoral Sanctions Identifications (SSI) List, the Foreign Sanctions Evaders (FSE) List, the Non-SDN Menu-Based Sanctions (NS-MBS) List, the Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List, the Non-SDN Palestinian Legislative Council (NS-PLC) List, and the Correspondent Account or Payable-Through Account Sanctions (CAPTA) List.
A critical companion rule: the 50% rule. OFAC treats any entity owned 50% or more, directly or indirectly, by one or more blocked persons as blocked itself — even when that entity is not named on any list. Screening names alone is not enough; ownership matters.
The BIS lists (Commerce)
The Bureau of Industry and Security controls exports of goods, software, and technology and publishes its own lists under the Export Administration Regulations:
- Entity List — foreign parties subject to specific license requirements for receiving U.S. items, usually for national-security or foreign-policy reasons.
- Denied Persons List — parties who have lost their export privileges; dealing with them in export transactions is prohibited.
- Unverified List — parties BIS could not verify in past transactions, triggering extra due-diligence steps.
- Military End User (MEU) List — parties for which exports of certain items are restricted because of military-end-use concerns.
The State Department list
The Directorate of Defense Trade Controls (DDTC) maintains the AECA Debarred List — parties barred from participating in defense-article exports under the Arms Export Control Act and ITAR.
The lists at a glance
| List | Agency | What it means in practice |
|---|---|---|
| SDN List | OFAC | Assets blocked; no dealings with U.S. persons |
| Consolidated (SSI, FSE, NS-MBS, NS-CMIC, NS-PLC, CAPTA) | OFAC | Narrower, program-specific prohibitions |
| Entity List | BIS | License required to export listed items |
| Denied Persons List | BIS | No export dealings permitted |
| Unverified List | BIS | Heightened due diligence required |
| Military End User List | BIS | Restricted exports for military end use |
| AECA Debarred List | State/DDTC | Barred from defense-trade transactions |
How to screen before you trade
You do not need every agency’s raw data files to comply. Practical screening looks like this:
- Use the free government tools. OFAC’s Sanctions List Search runs fuzzy-logic name matching across the SDN and Consolidated lists. The government’s Consolidated Screening List combines several agencies’ lists into one searchable resource for a first pass.
- Screen all parties to the deal — buyer, seller, end user, freight forwarder, bank, and any intermediary — not just your direct customer.
- Apply the 50% rule by checking ownership, not just names.
- Re-screen before each transaction and whenever lists update; designations and removals happen frequently.
- Keep records of what you screened, when, and the result. Documentation is your evidence of a good-faith program.
A hit is not always a hard stop — some matches are false positives, and some listed parties can be dealt with under a specific or general license. But a hit always means stop and verify before proceeding. For help building or stress-testing a screening process, see our International Trade Law practice, and for the difference between a country-wide ban and a targeted listing, see trade embargo vs. sanctions.
Frequently asked questions
What is the difference between the SDN List and the Consolidated List? The SDN List blocks parties outright — no dealings, assets frozen. The Consolidated List collects OFAC’s narrower programs, where only specific activities (such as certain financing or sectors) are restricted rather than all dealings.
How often are the sanctions lists updated? Frequently — sometimes several times a week. That is why screening must be repeated rather than done once at onboarding.
Do I have to screen against the BIS lists if I only sell domestically? If goods, software, or technology may ultimately be exported or re-exported, BIS rules can apply. Many businesses screen against both OFAC and BIS lists to be safe.
What is the 50% rule? OFAC treats an entity as blocked if blocked persons own 50% or more of it, directly or indirectly — even if the entity itself is not named. You must check ownership, not just the company name.
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