OFAC restricted-party screening (broader than SDN)

Description

SDN-list screening is the baseline of US sanctions compliance, and it is necessary but not sufficient. OFAC maintains several other restricted-party lists with different legal effects and different prohibited activities: the Sectoral Sanctions Identifications (SSI) list, which prohibits specific transaction types (typically debt or equity beyond certain tenors) with named entities in Russia, Venezuela, and elsewhere; the Foreign Sanctions Evaders (FSE) list, which targets parties found to have facilitated sanctioned conduct; the Non-SDN Palestinian Legislative Council list (NS-PLC); and the Non-SDN Menu-Based Sanctions list (NS-MBS), which carries activity-tier-specific prohibitions under the Caesar Act and other authorities. The Military End User (MEU) list under the EAR is technically an export-control list rather than an OFAC list, but operates in the same compliance workflow. The operational consequence is that a vendor that screens only against SDN is missing a meaningful slice of the prohibited counterparty universe, and the missed slice is the part where the prohibitions are activity-specific rather than blanket, which makes the violations harder to spot through a transactional review and easier to build into a routine commercial pattern. Modern screening vendors cover all of these lists by default; the operator's job is verifying that the vendor configuration actually has the full set enabled and that the screening cadence catches list updates.

Applicability

Applies when: markets include US.

How predicates are evaluated

Required by (1 regulation)

• US OFAC

  31 CFR Part 501 + program-specific (Iran 535, NK 510, Syria 542, Cuba 515, Crimea/DNR/LNR 589, Russia 587) — country-based + targeted-list + 50% Rule screening; geo-IP + self-declared-residency + beneficial-ownership data.

  31 CFR Part 501 + program-specific (Iran 535, NK 510, Syria 542, Cuba 515, Crimea/DNR/LNR 589, Russia 587)

Fulfilled by (2)

• comply-advantage · full · medium effort · $$
• refinitiv · full · high effort · $$$

ClearLaunch does not accept payment from vendors. Methodology.

Evidence formats

• restricted-party screening logs