SDN List (OFAC)
The US Treasury's main sanctions list, which freezes the assets of listed persons and entities and prohibits any transaction with them; the 50 percent rule extends it to companies they own.
The Office of Foreign Assets Control of the US Treasury publishes and continuously updates the list of Specially Designated Nationals and Blocked Persons. It gathers, under multiple programs, countries, terrorism, narcotics, cyber, human rights, proliferation, several thousand individuals, companies, vessels, aircraft and crypto-asset addresses. Listing blocks all their property under US jurisdiction and prohibits any US person from carrying out any transaction with them, directly or indirectly. An essential rule, known as the 50 percent rule, automatically extends blocking to any entity owned 50 percent or more, individually or in aggregate, by listed persons, even if it does not itself appear on the list. The reach extends beyond the United States through the dollar, US subsidiaries and secondary sanctions. The US regime is one of strict civil liability: a violation, even unintentional, can be penalized, good faith and the quality of the compliance program affecting only the amount. For insurance, the list is the primary basis for screening insureds, beneficiaries, counterparties and vessels. It is combined with EU, UK and UN lists, which do not always coincide.
On February 23, 2024, OFAC added the Russian state-owned shipping company Sovcomflot to the list and identified fourteen of its crude oil tankers as blocked property. A marine insurer, reinsurer or P&I club subject to US jurisdiction can no longer cover these vessels, and any indemnity owed must be paid into a blocked account.
- OFAC, Specially Designated Nationals and Blocked Persons List
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