April 29, 2024 · Updated August 8, 2026 · The CompliAPI team
SDN vs Non-SDN: OFAC's Two Sanctions Lists, Explained
SDN means blocked — assets frozen, no US dealings. Non-SDN means restricted, not blocked. What each OFAC list requires, in plain English.

The difference in one breath: an SDN match means blocked. OFAC's Specially Designated Nationals 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 — 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.
What "SDN" means on the OFAC list
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, 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.
Non SDN definition: 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. 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.
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.
What to do when you get a match
A workable analyst playbook, independent of tooling:
- 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.
- Read which list produced the match. This is the fork in the road: SDN means block-and-report; Non-SDN means program analysis.
- 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.
- 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.
- Re-screen on a schedule. Both lists change irregularly, and parties move between them — designations get upgraded to SDN, amended, or removed.
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.
Frequently asked questions
Is the Non-SDN list part of the SDN list?
No. OFAC publishes them separately: the SDN list in its own data files (sdn.csv, sdn.xml, sdn_advanced.xml) and the Non-SDN lists together in the Consolidated Sanctions List files (cons_prim.csv, consolidated.xml). A party appears on both only if it is separately designated under each authority.
Are Non-SDN entities blocked?
Generally no. A Non-SDN designation restricts specific activities — buying or selling a CMIC company's publicly traded securities, dealing in an SSI entity's new debt beyond a set maturity, maintaining a correspondent account for a CAPTA-listed bank — but the party's assets are not frozen, and dealings outside the restricted activity can remain lawful.
Where do I download each list?
Both are published free on OFAC's website under Sanctions List Files: the SDN list as sdn.csv and sdn.xml (plus sdn_advanced.xml), and the Non-SDN lists combined in the Consolidated Sanctions List as cons_prim.csv and consolidated.xml. OFAC's Sanctions List Search tool queries both at once.
How often do the lists change?
Irregularly. OFAC publishes designations, amendments and removals as enforcement actions happen — sometimes several times in a week, sometimes not for weeks. There is no fixed schedule, which is why screening pipelines poll for changes; CompliAPI checks OFAC's change feed every 15 minutes.
What is the SDN and non SDN difference in practice?
SDN means blocked: freeze any property you hold, stop the transaction, and report to OFAC. Non SDN means restricted: only the activity named by the listing program — securities purchases, new-debt dealings, correspondent accounts — is prohibited, and unrelated dealings can remain lawful. Operationally, a match is only actionable if it names which list produced it.