Today the Office of Foreign Assets Control (“OFAC”) updated its Specially Designated Nationals List (“SDN List”). OFAC frequently updates the SDN List to add or remove names as necessary and appropriate.
The SDN List is a list published by OFAC that includes the names 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.
OFAC implements and imposes sanctions against those companies and individuals on the SDN List. Any US citizen, permanent resident alien, entity organized under the laws of the United States (including foreign branches), or any person (i.e., individual or entity) in the United States (collectively, “U.S. persons”) are generally prohibited from dealing with these companies and individuals, including transactions involving commerce, business, trade or finance. U.S. persons must block any property in their possession or under their control in which a company or individual on the SDN List has an interest.
When doing business with a foreign company or individual, it is important to access the SDN List to ensure that transactions with that foreign party are permissible. U.S. persons are expected to exercise due diligence in determining whether any such persons are involved in a proposed transaction. A failure to review the most up-to-date SDN List and review current sanctions can lead to serious consequences.