SDN vs Non-SDN: OFAC's Two Sanctions Lists, Explained

SDN stands for Specially Designated Nationals — OFAC's Specially Designated Nationals and Blocked Persons List. The difference in one breath: an SDN match means blocked. The SDN list names parties whose assets in US jurisdiction are frozen and with whom US persons are generally prohibited from dealing at all. A Non-SDN match means restricted, not blocked — a match on the OFAC Non-SDN list (the Consolidated Sanctions List, which OFAC publishes as separate non-SDN lists): "non-SDN" means not on the Specially Designated Nationals list but on one of OFAC's other lists, where only specific activities are prohibited, such as securities investment or new-debt dealings, depending on which Non-SDN list produced the match.

That one distinction drives everything an analyst does next: an SDN hit obliges you to block and report; a Non-SDN hit obliges you to check whether your specific transaction is the restricted kind. This post walks through what each designation means, which Non-SDN lists actually exist, and what to do when a screen comes back positive.

Looking for the files themselves? Download URLs, schemas and parsing code for every OFAC export — sdn.csv, sdn.xml, sdn_advanced.xml for the SDN list and cons_prim.csv, consolidated.xml, cons_advanced.xml for the Non-SDN Consolidated list, including the legacy treasury.gov/ofac/downloads paths — are in our OFAC export files guide. This post covers what the two lists mean.

What does SDN stand for in OFAC?

SDN stands for Specially Designated National. The SDN and Blocked Persons List is maintained by the Office of Foreign Assets Control (OFAC), part of the US Treasury (what OFAC is and does), and names the individuals, companies, vessels, aircraft — and increasingly crypto wallet addresses — designated under US sanctions programs for involvement in terrorism, narcotics trafficking, weapons proliferation, cyberattacks and other conduct targeted by US foreign policy.

The legal consequence of an SDN designation is full blocking sanctions:

• Assets are frozen. Any property or interest in property of an SDN that comes within US jurisdiction must be blocked and reported to OFAC — it cannot be transferred, paid out, or returned.
• Dealings are prohibited. US persons — citizens, permanent residents, entities organized in the US, and anyone physically in the US — are generally prohibited from transacting with SDNs entirely, absent an OFAC license.
• Ownership propagates. Under OFAC's 50 Percent Rule, an entity owned 50% or more, individually or in the aggregate, by one or more blocked persons is itself blocked, even if it never appears on the list by name.

That is why an SDN match is the highest-severity screening result there is: the default response is to stop the transaction, freeze what you hold, and report.

SDN vs blocked person. An SDN is a party OFAC has listed by name. A blocked person is the wider legal category: every SDN, plus any entity whose property is blocked because of the 50 Percent Rule (OFAC FAQ 401) or a blocking order, whether or not it ever appears on the list. Every SDN is a blocked person; not every blocked person is an SDN — which is why screening the list is necessary but not sufficient where ownership is in play.

Non SDN list meaning: restricted, not blocked

A Non-SDN designation means OFAC has imposed targeted restrictions on a party without blocking it. The party's assets are not frozen, and US persons are not banned from dealing with it in general — instead, a specific menu of activities is prohibited, defined by whichever program the party is listed under.

Two realistic examples show the contrast:

• A US broker screens a counterparty and gets a hit on the NS-CMIC list (Chinese Military-Industrial Complex Companies). US persons are prohibited from purchasing or selling that company's publicly traded securities and derivatives of them — but the designation does not freeze the company's assets or bar unrelated commercial dealings like buying its consumer products.
• A US bank screens a payment and the originator matches the SDN list. Here there is no activity analysis to do: the payment must be blocked, the funds held in a blocked account, and a report filed with OFAC — generally within 10 business days.

Same screening pipeline, completely different obligations. This is why a match result that doesn't tell you which list produced it is operationally useless.

The difference between SDN and non SDN at a glance

	SDN List	Non-SDN lists
Legal effect	Full blocking sanctions	Targeted restrictions that vary by list and program
Asset blocking	Yes — property in US jurisdiction is frozen and reported	Generally no — assets are not frozen
Who must comply	All US persons, for essentially all dealings	Varies: US investors (NS-CMIC), counterparties in new debt/equity (SSI, NS-MBS), US financial institutions (CAPTA, NS-PLC)
Typical match action	Block or reject, hold funds, report to OFAC	Identify the program, check whether your transaction is the restricted activity, document the decision
Published as	sdn.csv, sdn.xml, sdn_advanced.xml	Consolidated Sanctions List: cons_prim.csv, consolidated.xml, cons_advanced.xml

Looking for the files themselves? Our sdn_advanced.xml guide covers the download locations, the advanced schema and working parsing code.

The consolidated non SDN list, specifically

"The Non-SDN list" is really a family of lists, which OFAC publishes together as the Consolidated Sanctions List. As of 2026 it includes:

• SSI — Sectoral Sanctions Identifications List. Entities in designated sectors of the Russian economy (financial services, energy, defense). Restrictions target new debt and equity beyond maturities set per directive, not all dealings.
• NS-CMIC — Non-SDN Chinese Military-Industrial Complex Companies List (the non-SDN CMIC list). US persons may not purchase or sell the listed companies' publicly traded securities, or derivatives of those securities.
• NS-MBS — Non-SDN Menu-Based Sanctions List. Parties sanctioned under menu-based authorities (such as CAATSA), where OFAC selects specific restrictions — for example on banking transactions or foreign exchange — from a statutory menu, person by person.
• NS-PLC — Non-SDN Palestinian Legislative Council List. US financial institutions must reject (not block) certain transactions involving listed PLC members.
• FSE — Foreign Sanctions Evaders List. Foreign parties found to have evaded US sanctions on Syria or Iran; US persons are generally prohibited from dealing with them, but their assets are not blocked.
• CAPTA — Correspondent Account or Payable-Through Account Sanctions List. Foreign financial institutions for which US banks must close or strictly condition correspondent and payable-through accounts.

A person on the SSI list, a person on the CAPTA list and a person on the NS-CMIC list are each not on the SDN list but may still restrict dealings — all of the above are Non-SDN designations, and a screen that only reads the SDN file misses every one of them. The FSE and SSI lists do not replace the SDN list; they sit beside it in the Consolidated files.

Examples of non-SDN sanctioned companies

Two entries from the live Consolidated list, verified against CompliAPI's search on October 3, 2026:

• Huawei Technologies Co., Ltd. — US OFAC Consolidated (non-SDN), program tag CMIC-EO13959 (the NS-CMIC list), OFAC record 30947. The listing prohibits US persons from buying or selling the company's publicly traded securities; it does not freeze Huawei's assets or bar unrelated dealings such as buying its products.
• OAO Novatek — US OFAC Consolidated (non-SDN), program tag UKRAINE-EO13662 (the SSI list), OFAC record 17064. The restriction is on dealing in the company's new debt beyond the maturity limit its SSI directive sets, not on all transactions — while a separate group company, Limited Liability Company Novatek Murmansk, sits on the SDN list under RUSSIA-EO14024 (record 47938) and is fully blocked. Same corporate family, two lists, two obligations.

A no-match on either list says nothing about the 50 Percent Rule. To check a specific name against both lists right now, the free SDN search tool runs on the same live data.

If someone searching "non sdn list" is hunting for the artifact itself: it is the Consolidated Sanctions List download on OFAC's site, published alongside — but separate from — the SDN files. CompliAPI ingests it as its own list — CompliAPI's Consolidated list data source covers the six constituent lists, the cons_prim.csv / consolidated.xml / cons_advanced.xml files and the ofac_consolidated slug every match carries.

Both lists designate parties — people, companies, vessels, wallet addresses. If your question is about places — which countries are comprehensively embargoed, and which sit under selective programs like Venezuela's or Belarus's — that's a different (and frequently misunderstood) artifact entirely: see our OFAC sanctioned countries reference, which links every country to the program behind it.

What to do when you get a match

A workable analyst playbook, independent of tooling:

1. Confirm the identity match first. Name-only hits are false-positive-prone; identifier-level matches (a wallet address, passport number, or email published in the designation) are near-conclusive. For wallet addresses specifically, see how to check if a crypto wallet is sanctioned.
2. Read which list produced the match. This is the fork in the road: SDN means block-and-report; Non-SDN means program analysis.
3. For SDN matches: stop the transaction, block property you hold, and report to OFAC (blocked-property reports are generally due within 10 business days). Escalate per your policy.
4. For Non-SDN matches: identify the program (SSI directive, CMIC securities ban, CAPTA account restriction…) and check whether your transaction is the restricted activity. Unrelated dealings may lawfully proceed — document the analysis either way.
5. Re-screen on a schedule. Both lists change irregularly, and parties move between them — designations get upgraded to SDN, amended, or removed (CompliAPI publishes recent delistings as they are ingested).

The operational challenge underneath all of this is freshness and provenance: OFAC publishes changes as files, on no fixed schedule. CompliAPI's OFAC API automates that pipeline for both lists — ingesting the official SDN data every 15 minutes alongside the Consolidated (non-SDN) list, which rides the same publication stream — and returning the list name and official source record with every match, so step 2 of the playbook is answered by the response itself. (Screening also covers the EU's consolidated financial sanctions list, which draws a similar line between asset-freeze designations and narrower restrictive measures.) For a one-off manual check of either OFAC list, the free SDN search tool queries the same live data — names, companies, and crypto addresses, no signup.

This article is general information about how OFAC's lists work, not legal advice. What a specific match obliges your organization to do depends on your jurisdiction, license posture and facts — determine that with qualified counsel.