# Office of Foreign Assets Control Sanctions (OFAC) Compliance Trade, Export Controls & Sanctions ###### 🇺🇸 OFAC Sanctions ## The SDN List Changes Weekly. Are You Screening Every Supplier, Customer, and Transaction Against It? OFAC sanctions compliance requires continuous screening of every business relationship against multiple sanctions lists—with strict liability for violations, even unintentional ones. The SDN List contains tens of thousands of designations. Penalties reach $377,700 per violation or twice the transaction value. Criminal penalties include 20 years imprisonment. Certivo automates OFAC sanctions screening from supplier onboarding to continuous audit-ready documentation. **1,300+** New OFAC designations in 2025 alone **$377,700** Maximum civil penalty per violation (IEEPA, inflation-adjusted) **50%** Ownership threshold triggering blocked status under the 50 Percent Rule ## Regulation Overview **Jurisdiction** United States (with extraterritorial reach to non-U.S. persons in certain programs) **Regulatory Body** U.S. Department of the Treasury — Office of Foreign Assets Control (OFAC) **Regulation Number** Effective Date OFAC established 1950; IEEPA enacted 1977; programs continuously updated **Official Source** [https://ofac.treasury.gov/](https://ofac.treasury.gov/) **Key Threshold** Strict liability—no knowledge or intent required for civil violations # What Are OFAC Sanctions? OFAC administers and enforces U.S. economic and trade sanctions programs targeting foreign countries, regimes, terrorists, narcotics traffickers, weapons proliferators, and other threats to U.S. national security. For supply chain and compliance teams, OFAC sanctions compliance means screening every counterparty—suppliers, customers, freight forwarders, financial intermediaries—against multiple sanctions lists before and during every transaction. OFAC maintains the Specially Designated Nationals and Blocked Persons List (SDN List), the Sectoral Sanctions Identifications List (SSI List), the Non-SDN Menu-Based Sanctions List, the CAPTA List, and the Non-SDN Communist Chinese Military Companies List. The SDN List alone contains tens of thousands of entries and is updated multiple times per week. OFAC added over 1,300 designations in 2025. OFAC sanctions compliance requires real-time screening infrastructure, beneficial ownership analysis under the 50 Percent Rule, and continuous monitoring as lists change. A single unscreened transaction with a sanctioned party creates strict liability exposure—regardless of intent. ## Key Components / Sub-Frameworks | Obligation | Description | |------------|-------------| | All assets blocked; no transactions permitted with U.S. nexus | SDN List - Specially Designated Nationals and Blocked Persons | | Restrictions on specific transaction types (debt, equity) with listed entities | SSI List - Sectoral Sanctions Identifications | | Entities 50%+ owned by one or more SDNs are treated as blocked, even if unlisted | 50 Percent Rule - Ownership-based blocking | | Broad prohibition on nearly all transactions involving targeted countries | Comprehensive Sanctions - Country-wide embargoes (Cuba, North Korea, Iran, Syria-related programs evolving) | | Prohibitions vary by program; screening required for all | List-Based Sanctions - Targeted designations across 30+ programs | | Must verify applicability; easily revocable | General Licenses - OFAC-issued authorizations for otherwise prohibited activities | ## OFAC Designated 1,300+ Entities in 2025 and Issued 14 Enforcement Actions—Including a $216M Penalty. Is Your Screening Current? OFAC enforcement intensified in 2025 with record penalties against investment advisers, digital asset exchanges, and other entities. DOJ named sanctions evasion a top-10 white-collar enforcement priority. FinCEN launched a whistleblower portal in February 2026. Compliance programs relying on periodic screening are already out of date. ## Key Compliance Requirements # Who Must Comply - All U.S. citizens and permanent residents, worldwide - All entities organized under U.S. law, including foreign branches - Non-U.S. persons engaging in transactions with a U.S. nexus - Non-U.S. entities owned or controlled by U.S. persons - Foreign financial institutions processing U.S. dollar transactions - Any person causing a U.S. person to violate sanctions (facilitation) # Key Thresholds #### Strict liability Civil violations require no knowledge or intent—accidental transactions carry full penalty exposure #### 50% ownership Entities owned 50%+ by one or more SDNs are automatically blocked #### $377,700 per violation Maximum civil penalty per violation under IEEPA (2025 inflation-adjusted); or twice transaction value #### $1M / 20 years Maximum criminal penalties for willful violations ## Core Obligations 1. **Sanctions Screening** Screen all counterparties against SDN List, SSI List, and consolidated sanctions lists **DEADLINE** Before every transaction; continuous monitoring 2. **Beneficial Ownership Analysis** Determine whether counterparties are 50%+ owned by SDNs **DEADLINE** At onboarding and upon list updates 3. **Asset Blocking** Block all property and interests in property of SDNs within U.S. jurisdiction **DEADLINE** Immediately upon identification 4. **Reporting** File blocking reports with OFAC within 10 business days of blocking **DEADLINE** Within 10 business days 5. **Recordkeeping** Maintain records of all sanctions-related compliance actions **DEADLINE** 5 years minimum ## OFAC-Specific Pain Points ###### The List Update Tsunami OFAC updates the SDN List multiple times per week. In 2025, over 1,300 new designations were added—spanning cartels, scam networks, shadow fleet vessels, and sanctioned government officials. Your screening ran Monday. A new designation published Tuesday. Your payment processed Wednesday. You are now in violation. ###### The 50 Percent Rule Blind Spot An SDN owns 30% of Company A. A second SDN owns 25% of Company A. Neither ownership exceeds 50%, but aggregate SDN ownership is 55%—making Company A blocked property. Without beneficial ownership analysis across your entire supplier base, you cannot identify these indirect exposures. ###### The Strict Liability Trap OFAC enforces civil penalties on a strict liability basis. Your compliance team screened the supplier name but missed a subsidiary three tiers deep that is 60% owned by an SDN. The payment clears. OFAC identifies the violation. Intent is irrelevant. Penalty exposure is immediate—up to $377,700 per transaction or twice the value. ###### The Multi-Program Complexity OFAC administers over 30 sanctions programs—each with different prohibitions, general licenses, and exceptions. Russia-related sanctions differ from Iran sanctions. Cuba comprehensive sanctions differ from Venezuela sectoral restrictions. Your compliance team needs program-specific expertise for every transaction, across every supplier relationship, continuously. ## Certivo in Action ## Certivo in Action—OFAC Sanctions Workflow GET EVIDENCE IN Screen Every Supplier and Counterparty Against OFAC Lists—Continuously, Not Just at Onboarding CORA screens suppliers, customers, and intermediaries against the full OFAC sanctions dataset, collects beneficial ownership declarations, and flags matches automatically. ## MAKE SENSE OF IT Know Instantly When a Supplier, Customer, or Sub-Tier Entity Triggers Sanctions Risk ## PROVE COMPLIANCE OUT Demonstrate Due Diligence to Auditors, Legal Counsel, and Regulators in Hours, Not Weeks ## One Supplier Submission. Screening Against All OFAC Lists. Audit-Ready in Hours. Certivo collects supplier data and beneficial ownership declarations, screens against the complete OFAC sanctions dataset with alias resolution and 50 Percent Rule calculations, and generates audit-ready compliance documentation automatically. When OFAC publishes new designations, Certivo res screens your entire counterparty base and alerts you—before transactions process. ## Features Tabs ### Counterparty Screening Certivo's automated campaigns achieve 95% response rates for beneficial ownership declarations vs. 20-30% with manual outreach. ### Entity Resolution & Matching Every entity screened with fuzzy logic, alias resolution, and transliteration matching—minimizing false negatives without drowning in false positives. ### OFAC List Monitoring Always screened against the current sanctions lists—not your last quarterly run. ### Compliance Documentation Generate OFAC compliance reports and blocking filings in hours instead of weeks. ### Multi-Program Risk Assessment Every transaction assessed against the correct program-specific prohibitions and general licenses. ## Related Regulations - **EAR (Export Administration Regulations)** BIS Entity List and Denied Persons List complement OFAC SDN screening Combined Value Single screening workflow covers OFAC and BIS restricted party lists - **ITAR** Defense trade sanctions intersect with OFAC country embargoes Combined Value Unified trade compliance screening for both OFAC and ITAR-restricted destinations - **EU Sanctions** EU maintains separate but often overlapping sanctions lists Combined Value Multi-jurisdiction screening validates against OFAC, EU, and UN lists simultaneously - **UFLPA** Forced labor restrictions complement OFAC's Xinjiang-related designations Combined Value Combined supplier screening covers both forced labor and sanctions exposure - **Anti-Money Laundering (AML/BSA)** FinCEN reporting obligations intersect with OFAC blocking and reporting Combined Value Integrated compliance evidence supports both OFAC screening and AML due diligence - **Conflict Minerals (3TG)** OFAC sanctions on conflict regions overlap with 3TG sourcing restrictions Combined Value Unified supplier risk scoring across sanctions, conflict minerals, and ethical sourcing ## Industries Most Impacted ### Aerospace & Defense Your Pain Point ITAR/OFAC overlap; complex sub-tier supply chains; government contract requirements ### Electronics Manufacturing Your Pain Point Semiconductor restrictions; China/Russia-linked entity exposure; rapid designation changes ### Automotive Manufacturing Your Pain Point Global supply chains spanning sanctioned regions; EV battery mineral sourcing ### Energy & Infrastructure Your Pain Point Russia shadow fleet sanctions; Iran energy sector restrictions; Venezuela general licenses ### Industrial & Heavy Equipment Your Pain Point Dual-use equipment risks; global distributor networks; end-use monitoring ### Pharmaceuticals & Biotech Your Pain Point Humanitarian exemptions; complex licensing for sanctioned-country shipments ### Government & Public Sector Your Pain Point Federal procurement requires OFAC compliance evidence from all contractors ### Semiconductor & High-Tech Your Pain Point Entity List / SDN overlap; technology transfer restrictions; secondary sanctions risk ## Return on Investment **80%** Reduction in Screening Labor From Manual List Checks to AI-Native Compliance Automation **4 Hours** To Audit-Ready Package Screening Documentation Acceleration **Real-Time** SDN List Sync Proactive OFAC Sanctions Monitoring ## Key Statistics - **30+** OFAC sanctions programs screened with continuous list sync - **99.2%** Entity screening accuracy with fuzzy matching and alias resolution - **95%** Supplier response rate for ownership declarations with CORA-powered campaigns ## Frequently Asked Questions **Who must comply with OFAC sanctions regulations?** All U.S. persons—citizens, permanent residents, entities organized under U.S. law, and their foreign branches—must comply with OFAC sanctions. Non-U.S. persons face exposure when transactions involve U.S. dollar clearing, U.S.-origin goods, or any U.S. nexus. Secondary sanctions in certain programs (Iran, Russia) extend reach to non-U.S. entities. Certivo screens your entire counterparty base and maps jurisdictional exposure across all active OFAC programs. **What are the penalties for OFAC sanctions violations?** Civil penalties under IEEPA reach the greater of $377,700 per violation (inflation-adjusted) or twice the transaction value. Criminal penalties for willful violations include fines up to $1 million and imprisonment up to 20 years. OFAC's 2025 enforcement included a $216 million settlement against a single investment adviser. Strict liability applies—meaning even accidental, unintentional violations carry full civil penalty exposure. **How does Certivo handle the OFAC 50 Percent Rule?** Certivo collects beneficial ownership declarations from suppliers and cross-references them against OFAC designations. CORA calculates aggregate SDN ownership across multiple blocked persons to identify entities that are blocked by operation of the 50 Percent Rule—even when no single SDN holds a majority stake. This goes beyond name matching to capture the ownership-based exposure that OFAC expects companies to identify. **How does Certivo keep screening current as OFAC lists change?** Certivo maintains real-time sync with all OFAC sanctions lists—SDN, SSI, consolidated non-SDN lists, and program-specific designations. When OFAC publishes new designations or removes entries, Certivo automatically rescreens your entire counterparty base and alerts you to new matches. This continuous monitoring replaces the periodic batch-screening approach that creates gap exposure between runs. **How does OFAC screening relate to EAR, ITAR, and other export control compliance?** OFAC sanctions, BIS Entity List (EAR), ITAR restrictions, and EU sanctions lists all target overlapping but distinct sets of restricted parties. A single supplier may appear on multiple lists under different programs. Certivo screens against OFAC, BIS, and EU restricted party lists simultaneously from one supplier submission—providing multi-jurisdiction screening that eliminates duplicate screening workflows across trade compliance programs. ## Ready to Automate OFAC Sanctions Compliance? See how Certivo's sanctions compliance software transforms restricted party screening from periodic manual checks to continuous, audit-ready confidence.