What is the difference between the USA and the OFAC lists?
Screena sources several lists to comply with U.S. sanctions regulations and trade restrictions.
US OFAC Specially Designated Nationals (SDN) List
As part of its enforcement efforts, the Office of Foreign Assets Control (OFAC) publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. Collectively, such individuals and companies are called "Specially Designated Nationals" or "SDNs." Their assets are blocked and U.S. persons are generally prohibited from dealing with them. View more information on Treasury's Sanctions Programs.
To make it easier to comply with OFAC's sanctions regulations, the Office of Foreign Assets Control (OFAC) is offering all of its non-SDN sanctions lists in a consolidated set of data files "the Consolidated Sanctions List". 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.
The Consolidated Screening List (CSL) is a list of parties for which the United States Government maintains restrictions on certain exports, reexports, or transfers of items.
This list is published by the US International Trade Administration and consists of the consolidation of multiple export screening lists of the Departments of Commerce, State, and Treasury:
Authority
List
Department of the Treasury – Office of Foreign Assets Control
Capta List (CAP)
Department of the Treasury – Office of Foreign Assets Control
Non-SDN Chinese Military-Industrial Complex Companies List (CMIC)
Department of the Treasury – Office of Foreign Assets Control
Foreign Sanctions Evaders (FSE)
Department of the Treasury – Office of Foreign Assets Control
Non-SDN Menu-Based Sanctions List (NS-MBS List)
Department of the Treasury – Office of Foreign Assets Control
Specially Designated Nationals (SDN)
Department of the Treasury – Office of Foreign Assets Control
Sectoral Sanctions Identifications List (SSI)
Department of Commerce – Bureau of Industry and Security
Denied Persons List (DPL)
Department of Commerce – Bureau of Industry and Security
Entity List (EL)
Department of Commerce – Bureau of Industry and Security
Military End User (MEU) List
Department of Commerce – Bureau of Industry and Security
Unverified List (UVL)
Department of State – Bureau of International Security and Non-proliferation
ITAR Debarred (DTC)
Department of State – Directorate of Defense Trade Controls
The US OFAC Specially Designated Nationals (SDN) list and the US OFAC Consolidated (Non-SDN) list are already contained in the US Trade Consolidated Screening List (CSL).
However, unlike the OFAC SDN and OFAC Consolidated (Non-SDN) lists, the US Trade Consolidated Screening List (CSL) doesn’t specify whether an alias is either a strong or a weak/low-quality alias.
Suppose you wish to exclude weak/low-quality aliases when screening names and thus reduce false positives. In that case, you have to work with the original OFAC lists (i.e., the "OFAC SDN" and "OFAC CONSOLIDATED" datasets).
Please note that you can use Screena's attribute keywords combined with the algorithm keywordAlgo to screen on specific subsets of the US Trade Consolidated Screening List (CSL) to avoid overlaps with the OFAC lists, for instance.
In the early days of the massive new sanctions targeting Russian individuals and companies (i.e., around February 23, 2022), we found that the original US Trade Consolidated Screening List (CSL) was not systematically synchronized in real-time with the original OFAC lists.
While the ITA’s Data Services Platform promptly resolved this issue, we advise Screena users to rely on the original OFAC lists (i.e., the "OFAC SDN" and "OFAC CONSOLIDATED" dataset) to ensure strict compliance with OFAC's sanctions regulations.
