The Office of Foreign Assets Control’s Consolidated Sanctions List (Non-SDN List) combines records from multiple OFAC sanctions lists related to non-blocking sanctions. It provides a more convenient way to find out if an entity is sanctioned than searching individual non-SDN lists. All U.S. businesses must comply with sanctions against listed entities.
Sanctions screening against the Consolidated Sanctions List should be part of onboarding and customer due diligence for banks, money services businesses, FinTech companies, crypto companies, and any other business that risks transacting with sanctioned entities.
Which OFAC Sanctions Lists are Included?
The Consolidated Sanctions List collates records from OFAC sanctions lists except for the Specially Designated Nationals and Blocked Persons (SDN) List. The included Non-SDN lists are subject to change as the sanctions regime evolves, but at the time of writing, they include:
- Foreign Sanctions Evaders (FSE) List: Individuals and entities that have violated U.S. sanctions on Syria and Iran.
- Sectoral Sanctions Identifications (SSI) List: Specific sectors of the Russian economy.
- Palestinian Legislative Council (NS-PLC) List: Members of the Palestinian Legislative Council affiliated with terrorist organizations.
- List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List): Foreign financial institutions subject to restrictions or prohibitions on maintaining correspondent or payable-through accounts in the U.S.
- Non-SDN Menu-Based Sanctions List (NS-MBS List): Individuals and entities subject to selected sanctions determined by executive orders or legislation.
- Non-SDN Chinese Military-Industrial Complex Companies List (NS-CMIC List): Chinese military-industrial complex companies.
We explored each of these lists in An Overview Of OFAC Sanctions Lists.
What is the Relationship between the SDN List and Non-SDN Lists?
The SDN (Specially Designated Nationals and Blocked Persons) List includes individuals, companies, and other entities subject to blocking sanctions. U.S. businesses are prohibited from transferring, withdrawing, exporting, or otherwise dealing with assets or property of people and groups subject to blocking sanctions. That is, their assets and property are frozen.
In contrast, the Non-SDN lists included in the Consolidated Sanctions Lists are subject to a variety of restrictions that do not usually amount to the complete blocking of assets. They might include export controls, import bans, financial transaction restrictions, and sectoral sanctions against specific industries. They may, but do not necessarily involve the freezing of a sanctioned entity’s assets.
Consolidated Sanctions List vs Consolidated Screening List
The Consolidated Sanctions List and the Consolidated Screening List are two distinct resources used for compliance with U.S. regulations, each serving a different purpose.
As we’ve explained, the Consolidated Sanctions List compiles various non-SDN sanctions lists into one document. It focuses solely on sanctions, including individuals and entities subject to U.S. sanctions programs but not listed on the SDN list. It is essential for ensuring compliance with U.S. sanctions regulations.
The Consolidated Screening List (CSL) is a broader tool that aggregates export controls and relevant sanctions lists from different U.S. government departments, including the Department of Commerce, the Department of State, and the Treasury. It includes a wide range of restrictions, from trade embargoes and export controls to financial sanctions, making it a comprehensive resource for businesses to comply with various U.S. export controls and sanctions.
In essence, the Consolidated Sanctions List is narrowly focused on sanctions compliance, while the Consolidated Screening List provides a broader view of entities and individuals subject to a wider array of U.S. export controls and sanctions.
How Often is the Consolidated Sanctions List Updated?
The update frequency of OFAC sanctions lists varies, and so therefore does the frequency of the consolidated updates. Listed entities and the associated data may be changed several times a week or as infrequently as once a month, depending on the list and external circumstances. To minimize sanctions compliance risk, businesses should always screen against the most recent version.
What are the Consequences of Non-Compliance with the Consolidated Sanctions List?
Non-compliance with the Consolidated Sanctions List can result in significant civil and criminal penalties. Civil penalties vary by sanctions program but include steep fines for non-compliant transactions. Criminal penalties for sanctions list violations can include monetary fines ranging from a few thousand dollars to several million dollars, with multi-decade prison sentences for deliberate and repeated sanctions evasion.
It’s worth remembering that even accidental non-compliance is punishable. Lack of awareness of a client or customer’s sanctions status is not a defense. Businesses must implement effective know-your-customer and customer due diligence policies and procedures that include sanctions screening.
For additional information, view our blog outlining OFAC screening requirements best practices.
Sanctions Screening for Non-SDN Sanctions Lists
Alessa’s Watchlist and Sanctions Screening Software helps businesses with fast, accurate, and timely OFAC sanctions list screening. Our sanctions compliance solution provides:
- Global PEP and sanctions screening, including comprehensive OFAC list screening
- Real-time, periodic, and event-based screening
- Machine learning and rules-based analytics
- Configurable workflow management
- A sophisticated and configurable risk-scoring model
- Cost-effective sanctions data, where you only pay for the lists you use
Contact our AML and sanctions compliance experts today to learn how Alessa can streamline and optimize your sanctions compliance program.
