OFAC List (SDN List)

“OFAC list” most commonly refers to the Specially Designated Nationals and Blocked Persons List (SDN List), published and maintained by the US Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC administers and enforces US economic and trade sanctions programs under a range of statutory authorities (including the International Emergency Economic Powers Act and the Trading with the Enemy Act) and executive orders, targeting sanctioned countries, regimes, terrorist organizations, narcotics traffickers, weapons-of-mass-destruction proliferators, and other parties identified as national-security or foreign-policy threats.

The SDN List names specific individuals, companies, research institutions, non-profits, vessels, and aircraft. Anyone or anything on it is “blocked”: their property and interests in property that come within US jurisdiction must be frozen, and US persons — a category that includes US universities, their employees, and anyone physically in the United States — are generally prohibited from engaging in almost any transaction with them, directly or indirectly, without a specific license from OFAC. This is a materially broader prohibition than an export-control restriction on a specific controlled item: an SDN designation blocks essentially all dealings with that party, not just the transfer of a particular technology.

OFAC also maintains a Consolidated Sanctions List, which combines several narrower, program-specific lists (such as the Sectoral Sanctions Identifications List and the Non-SDN Menu-Based Sanctions List), and it administers country-based comprehensive sanctions programs — for example on Cuba, Iran, North Korea, Syria, and the Russia/Belarus-related programs adopted since 2022 — under which a transaction can be prohibited because of where a counterparty is located, even if that counterparty is never individually named on the SDN List.

Why research institutions screen against it

Universities and other research institutions are US persons for OFAC purposes, so the same prohibitions that apply to any US company or individual apply to them. In practice this means restricted-party screening — checking a prospective party’s name against OFAC’s lists using the Sanctions List Search tool, which applies fuzzy-name matching to catch near-matches and transliteration variants — before entering into an agreement or moving money or controlled items. Institutions typically screen:

• International research collaborators, co-investigators, and visiting scholars, before appointment or subaward execution.
• Foreign subrecipients, contractors, and vendors on sponsored projects.
• Payment counterparties — including, per OFAC’s own guidance to academic institutions, tuition payors and other third parties paying on a student’s behalf, since a blocked-person match on the payment side is itself a prohibited transaction.
• Parties to a material transfer agreement, equipment purchase, or international shipment tied to a research project.

A confirmed match against the SDN List (or a comprehensive country sanctions program) generally means the transaction cannot proceed without an OFAC license — either a general license already published for the relevant activity, or a specific license OFAC grants case by case. Screening is typically documented and repeated periodically, since OFAC updates its lists on an ongoing basis (new designations, delistings, and identifier updates), not just once at onboarding.

OFAC sanctions vs. EAR/ITAR export control — a distinction worth being precise about

OFAC sanctions and US export controls are administered separately, triggered by different facts, and frequently confused because both commonly appear in the same restricted-party screening workflow:

• OFAC sanctions are person- and country-based. They ask who the counterparty is (an SDN, a blocked person, a party in a comprehensively sanctioned country) and generally prohibit dealing with that party at all, regardless of what is being transferred.
• EAR and ITAR are item- and technology-based. They ask what is being exported, shared, or disclosed — a specific controlled item, technology, or technical data set — and to whom, including a release to a foreign national inside the US (a deemed export). A party can be entirely unsanctioned by OFAC and still be barred from receiving a specific ITAR- or EAR-controlled item under a separate licensing requirement.

The two regimes are administered by different Treasury, State, and Commerce Department components under different statutes, and a single international collaboration is routinely screened against both: an OFAC sanctions check on the counterparty’s identity and location, and a separate export-control classification and deemed-export analysis on the technology or data involved. See ITAR and EAR for how that second regime works, and export-controlled research for the broader operational picture of when a project is controlled at all.

OFAC vs. CFIUS

OFAC screening is also distinct from a CFIUS review. CFIUS examines whether a specific foreign investment or acquisition transaction poses a national-security risk through foreign control of, or governance rights in, a US business; OFAC sanctions instead prohibit dealing with a designated party or sanctioned jurisdiction outright, independent of any investment or acquisition structure. A foreign investor in a university spinout could clear CFIUS review entirely and still be an OFAC-blocked party if it (or a person with a qualifying ownership interest in it) appears on the SDN List — the two checks address different legal questions and neither substitutes for the other.

Worked examples

• A university’s sponsored-programs office runs a prospective foreign co-investigator through OFAC’s Sanctions List Search tool as a standard step before executing a subaward agreement for an international collaboration — routine restricted-party screening, independent of any export-control classification work done on the underlying technology.
• An institution’s bursar’s office declines a tuition payment because the third-party payor matches an SDN List entry; processing the payment would itself be a transaction with a blocked person, prohibited absent an OFAC license.

Counter-example

A visiting scholar’s home institution is located in a country subject to general political or export-control scrutiny, but neither the scholar nor their institution appears on the SDN List or any OFAC sanctions program. That is not an OFAC match — it may still raise a separate EAR/ITAR deemed-export question depending on what technology or data the scholar would access, but the two determinations are made under different criteria even when run as part of the same overall screening process.

Frequently asked questions

Is the “OFAC list” the same as an export control list?

No. The SDN List and OFAC’s other sanctions lists identify sanctioned persons, entities, and countries that US persons are generally barred from transacting with at all. Export control lists like the Commerce Control List and US Munitions List instead classify specific controlled items and technologies under the EAR and ITAR. A screening workflow often checks both, but they are legally separate determinations. See ITAR and EAR.

Does a match on the SDN List always mean a transaction is completely barred?

In most cases, yes, absent a license: dealings with a blocked person are prohibited unless authorized by a general license OFAC has already published for that type of activity, or by a specific license OFAC grants on application. Institutions facing a potential match typically involve export-control or general counsel staff before proceeding.

Who at a university is responsible for OFAC screening?

Practice varies by institution, but restricted-party screening (OFAC, plus related denied- and debarred-party lists) is typically coordinated by an export control office, sponsored programs office, or research compliance office, often using commercial or OFAC-provided screening tools rather than manual list checks.

References

• US Department of the Treasury, Office of Foreign Assets Control, “Specially Designated Nationals and Blocked Persons List (SDN) Human Readable Lists” (ofac.treasury.gov)
• OFAC, “Sanctions List Search” tool (sanctionssearch.ofac.treas.gov)
• OFAC, “Sanctions List Service” (ofac.treasury.gov/sanctions-list-service)