SDN vs SDGT vs sectoral sanctions — the OFAC list distinctions that matter
More than one list
When a verification tool says “OFAC check passed,” the implicit reference is usually the SDN list — the Specially Designated Nationals and Blocked Persons List. But OFAC publishes several distinct lists under different sanctions programs, and a search against the SDN alone misses persons and entities subject to non-SDN sanctions.
For commercial-finance verification, the categorization matters because the legal consequences of transacting with a person on each list are different. Knowing what’s actually in the list you’re matching against tells you what a “clean” result means.
The SDN list
The SDN list is the primary OFAC sanctions list. It is a consolidated list compiled across all major OFAC sanctions programs — Iran, Russia, North Korea, Syria, Venezuela, narcotics trafficking, terrorism, cybercrime, and others. A person or entity on the SDN list is “blocked” — meaning US persons cannot transact with them, the person’s US-jurisdiction assets are frozen, and there are no general licenses permitting routine transactions.
Roughly 13,000-14,000 persons and entities are on the SDN list as of 2026. The list is updated frequently — sometimes daily — and the most recent updates are published at home.treasury.gov/policy-issues/financial-sanctions/recent-actions.
For most credit-decision purposes, the SDN list is the right list to screen against. A clean SDN hit is the floor for OFAC compliance on a transaction.
The SDGT designation
“Specially Designated Global Terrorist” (SDGT) is not a separate list — it is a designation within the SDN list under Executive Order 13224, which authorizes Treasury to designate persons engaged in terrorism. Persons on the SDN list with the SDGT designation are the subset subject to terrorism-related sanctions.
The relevant distinction: SDGT is a more aggressive category in terms of secondary-sanctions exposure. The Anti-Terrorism Act and related statutes provide civil-liability exposure for entities that knowingly facilitate transactions involving SDGT-designated persons. Banks, in particular, face heightened diligence standards for SDGT-flagged transactions.
For commercial-finance processors, the distinction is mostly academic — if the SDN hit is positive, the transaction is blocked regardless of whether the underlying designation is SDGT or some other category. But if a downstream review is going to look at the file, knowing the designation specifically matters.
The SSI list
The Sectoral Sanctions Identifications (SSI) List is a separate list under specific Russia-related sanctions programs (Executive Orders 13662, 13685, 13883). Persons on the SSI list are subject to menu-based sanctions — meaning specific prohibited transaction types (e.g., debt or equity above certain maturities) rather than full blocking.
The practical effect for verification:
- A US person can engage in routine commercial transactions with an SSI-listed entity for goods or services.
- A US person cannot engage in restricted-financing transactions with the entity — typically debt or equity of long-dated maturity.
For most credit-decision purposes, this means an SSI hit is not an automatic block. It is a flag that requires checking whether the specific transaction type is prohibited under the particular sectoral sanctions applicable to the listed entity. The applicable Directive (1, 2, 3, 4 depending on the entity) tells you which transaction types are restricted.
This is the kind of analysis that typically requires consultation with sanctions counsel for a non-bank processor. The practical workflow: screen against SSI; if hit, escalate to counsel.
The Non-SDN MBS list
The Non-SDN Menu-Based Sanctions List (NS-MBS) is yet another list, used primarily for the China Military Industrial Complex Companies sanctions program (Executive Order 14032) and a small number of other programs. Persons on the NS-MBS list are subject to specific investment restrictions but are not fully blocked.
For most credit transactions outside the securities-investment context, NS-MBS is rarely relevant. For securities-related transactions, NS-MBS is critical.
The Foreign Sanctions Evaders list
The Foreign Sanctions Evaders (FSE) list identifies foreign persons that have engaged in deceptive practices to evade sanctions. Persons on the FSE list are typically not US persons; they are foreign nationals subject to restrictions that prevent US persons from facilitating their transactions.
For most US commercial-credit work, the FSE list is rarely relevant because the listed persons are foreign and not typically counterparties to US credit transactions. For international trade financing or letters of credit involving foreign persons, the FSE list matters.
The consolidated approach
OFAC publishes a “Consolidated Sanctions List” that combines the SDN, SSI, FSE, NS-MBS, and several other lists. For comprehensive screening, the Consolidated List is what to match against. The bulk download is available in CSV, XML, and other machine-readable formats at the OFAC site.
For a single API call to “screen this name against OFAC,” matching against the Consolidated List is the right default. Matching against the SDN alone is faster and covers the majority of blocking cases but misses sectoral-sanctioned entities. For non-bank processors, the SDN is often adequate; for transactions touching sectorally-sanctioned industries (Russian energy, Chinese tech, etc.), Consolidated is the right scope.
What “name match” actually catches
OFAC publishes name variations and aliases for many listed persons. A robust match algorithm needs to handle:
- Name variants (transliterations from non-Latin alphabets).
- Patronymic and naming-order conventions (Arabic, Spanish, Asian naming conventions).
- Aliases (“a.k.a.” entries — many SDN listings have 5+ aliases).
- Date-of-birth and place-of-birth supplemental data for disambiguation.
- Entity-name variations including legal-form indicators (“Ltd.”, “GmbH”, “LLC”).
A simple string-match catches the obvious cases. False positives (common names matching unrelated persons) and false negatives (slight spelling variations missing real hits) are both common with naive matching. Tools that use fuzzy matching with date-of-birth and country-of-origin disambiguation produce more reliable results.
What this means for you
For credit-decision use, screen against the OFAC Consolidated List, not the SDN alone. Know that a “clean” result on a non-Consolidated screen leaves sectoral-sanctioned persons unscreened. For non-routine sanctions exposure (transactions involving sanctioned-industry counterparties, foreign payments, cross-border financing), bring in sanctions counsel for the specific deal.
A VerifySOS lookup screens against the Consolidated List and surfaces designation specifics (SDN, SDGT, SSI Directive number, etc.) when there is a hit. Developers get the designation classification on the /api/v1/lookup response.