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QUESTION

What is the SDN list?

ANSWER

The Specially Designated Nationals and Blocked Persons ("SDN list") includes over 3,500 names of companies and individuals connected with the sanctions targets, that are based on the sanction programmes implemented by the OFAC. U.S citizens and permanent residents are prohibited from dealing with SDNs wherever they are located and all SDN assets are blocked. Since a number of the named individuals and entities are known to move from country to country and may end up in unexpected locations, it is important to check OFAC's website on a regular basis to ensure that your SDN list is current. This list hence answers the question of “Who do I know who not to do business with?” and U.S entities or individuals or entities are prohibited from transacting with SDNs without a license. OFAC issues two types of licenses that allows parties to engage in activities that would normally be prohibited. “General Licenses” make allowances for all U.S. persons for certain activities while “Specific Licenses” are issued to specific parties for specific transactions. These are granted for a variety of reasons but always require an application to OFAC.

Depending on the program, if the assets of an SDN enter into the U.S. or the U.S. financial system, those assets may simply be rejected or be “blocked.” Alongside with the SDN list, are the Country Sanction programmes, that are organized by country or region, and U.S-based companies should learn about the limitations of doing business with the stated country in the list, as each country has a unique set of restrictions.

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