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FIS Prime Databank Non-SDN Lists
Additional OFAC Saction Lists
In addition to its list of Specially Designated Nationals and Blocked Persons OFAC also maintains other, Non-SDN, sanctions lists. These lists are:
1. Sectoral Sanctions Identifications List2. Foreign Sanctions Evaders List3. Non-SDN Palestinian Legislative Council List4. Non-SDN Iranian Sanctions List5. The List of Foreign Financial Institutions Subject to Part 561 (the "Part 561 List")
1. Sectoral Sanctions Identifications (SSI) List
OFAC publishes a list of to identify persons operating in sectors of the Russian economy identified by the Secretary of the Treasury pursuant to Executive Order 13662. Directives found within the list describe prohibitions on dealings with the persons identified. A list of frequently asked questions on Sectoral Sanctions Identifications, including information on dealings with SSIs is available. The SSI List is not part of the Specially Designated Nationals (SDN) List. However, individuals and companies on the SSI List may also appear on the SDN List.
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2. Foreign Sanctions Evaders (FSE) List
OFAC publishes a list of foreign individuals and entities determined to have violated, attempted to violate, conspired to violate, or caused a violation of U.S. sanctions on Syria or Iran. It also lists foreign persons who have facilitated deceptive transactions for or on behalf of persons subject to U.S. sanctions. Collectively, such individuals and companies are called “Foreign Sanctions Evaders” or “FSEs.” Transactions by U.S. persons or within the United States involving FSEs are prohibited. A list of frequently asked questions on Foreign Sanctions Evaders, including information on dealings with FSEs is available. The FSE List is not part of the Specially Designated Nationals (SDN) List. However, individuals and companies on the FSE List may also appear on the SDN List.
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3. Palestinian Legislative Council (PLC) List
Section (b) of General License 4 issued pursuant to the Global Terrorism Sanctions Regulations (31 C.F.R. Part 594), the Terrorism Sanctions Regulations (31 C.F.R. Part 595), and the Foreign Terrorist Organizations Sanctions Regulations (31 C.F.R. Part 597) authorizes U.S. financial institutions to reject transactions with members of the Palestinian Legislative Council (PLC) who were elected to the PLC on the party slate of Hamas, or any other Foreign Terrorist Organization (FTO), Specially Designated Terrorist (SDT), or Specially Designated Global Terrorist (SDGT), provided that any such individuals are not named on OFAC's list of Specially Designated Nationals and Blocked Persons (SDN List). OFAC publishes a list of to identify individuals that are PLC members who were elected on the party slate of a FTO, SDT, or SDGT. These individuals do not, however, appear on the SDN List. As indicated above, transactions involving these individuals must be rejected.
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4. Non-SDN Iranian Sanctions Act (NS-ISA) List
On May 23, 2011, the U.S. President signed Executive Order (“E.O.”) 13574, “Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Sanctions Act of 1996, as Amended.” E.O. 13574 states that the Secretary of the Treasury, pursuant to authority under the International Emergency Economic Powers Act (“IEEPA”), shall implement certain sanctions that the Secretary of State imposes and selects under the pre-existing authority of the Iran Sanctions Act of 1996 (“ISA”) as amended by the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA”). In order to impose sanctions on persons determined to have made certain investments in Iran’s energy sector or to have engaged in certain activities relating to Iran’s refined petroleum sector OFAC has developed a list of persons that involves a prohibition on U.S. financial institutions making certain loans or credits as of the date of listing. This list can be found under the title “Non-SDN Iranian Sanctions Act (NS-ISA) List”.
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5. The List of Foreign Financial Institutions Subject to Part 561 (the Part 561 List)
List of CISADA and NDAA Prohibitions or Conditions. In order to implement certain provisions of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA), the National Defense Authorization Act of Fiscal Year 2012 (NDAA), the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) and certain executive orders, OFAC has developed a list of foreign financial Institutions that are subject to sanctions under these laws and orders. This list can be found under the title “The List of Foreign Financial Institutions Subject to Part 561 - the Part 561 List”.
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A. Consolidated Sanctions List Data Files
In order to make it easier to comply with OFAC's sanctions regulations, the office is now offering all of its non-SDN sanctions lists (including the Non-SDN, Palestinian Legislative Council List "NS-PLC List", the Part 561 List, the Non-SDN Iran Sanctions Act List "NS-ISA List", the Foreign Sanctions Evaders List "FSE List", and the Sectoral Sanctions Identifications List "SSI List") in a consolidated set of data files "the Consolidated Sanctions List". The goal of this consolidation effort is to reduce the number of list-related files that must be downloaded in order to maintain an automated sanctions screening program.
These consolidated files comply with all OFAC's existing data standards. In the future, if OFAC creates a new non-SDN style list, the office will add the new data associated with that list to these consolidated data files if appropriate. While the consolidated sanctions list data files are not part of OFAC's list of Specially Designated Nationals and Blocked Persons "the SDN List," the records in these consolidated files may also appear on the SDN List.
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B. Non-SDN List Distribution
Sectoral Sanctions Identifications (SSI) List and Foreign Sanctions Evaders (FSE) List have been added in our Specials List and are distributed together with any OFAC update distribution.
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