OFAC, or the Office of Foreign Assets Control within the US Treasury, administers and enforces United States economic sanctions programs primarily against countries and groups of individuals, such as terrorists and drug traffickers. Instead of comprehensive sanctions, selective sanctions can use the blocking of assets and trade restrictions to accomplish US foreign policy and national security goals.
OFAC SDN List
The Specially Designated Nationals and Blocked Person List (SDN List) is a list of individuals, organizations, companies, who the US government has determined to have acted against U.S. national security interests, foreign policy objectives, and more specifically U.S sanctions laws. The SDN List also includes aircrafts and vessels which the US has determined to be owned or controlled by SDNs.
Consequences of SDN Listing
For most individuals and companies listed on the OFAC's SDN List, the consequences of being identified as SDNs are severe and devastating. SDN listing means that U.S. persons and entities are prohibited from dealing with them. Due to the extraterritorial reach of U.S. jurisdiction, even non-US persons and entities will refuse to deal with and provide services to SDNs.
Persons active in international business are most at risk of losing access to their personal or business properties and funds, as banks may freeze bank accounts and block any property or funds held on behalf of SDNs and businesses may deny their services to such SDNs.
Removal from OFAC SDN List
In the removal process with OFAC, a strong case must be built for removal on the basis of a case of mistaken identity, or of a mistaken appreciation of evidence or that the circumstances of OFAC's claims against you have changed significantly.
Moreover, evidence of remedial or preventive action taken by the listed person should be included in a Request for Administrative Reconsideration or Petition for Removal from the OFAC SDN list.
