Understanding the global sanctions architecture
Sanctions screening requires checking against multiple lists maintained by different authorities. While there is significant overlap, each list reflects the foreign policy priorities of its issuing jurisdiction. Understanding these differences is essential for effective compliance screening - particularly for businesses operating across borders or dealing with international clients.
OFAC SDN list (United States)
The Specially Designated Nationals list is the largest of the major sanctions lists, and one of the most frequently updated.
Scope and jurisdiction
The OFAC Specially Designated Nationals (SDN) list is maintained by the US Treasury's Office of Foreign Assets Control. It contains the names of individuals and entities whose assets must be blocked, and with whom US persons are generally prohibited from dealing.
Extraterritorial reach
OFAC's jurisdiction extends beyond US borders due to the dominance of the US dollar in international commerce. Any transaction that touches the US financial system - including USD-denominated payments routed through US correspondent banks - falls within OFAC's jurisdiction. This means UK estate agents handling transactions with US dollar components and international law firms must consider OFAC compliance even if neither party is American.
EU consolidated list
The EU's consolidated list covers everyone subject to EU financial sanctions, across every EU sanctions regime.
Post-Brexit divergence
The EU sanctions map and consolidated list aggregates restrictive measures adopted by the Council of the European Union. Since Brexit, the UK and EU sanctions regimes have diverged - designations made by one may not be mirrored by the other. Research from the European Journal on Criminal Policy and Research highlights that this divergence creates compliance complexity for cross-border businesses.
Implications for non-financial institutions
TCSPs managing EU-incorporated entities, art dealers selling to EU-based collectors, and precious metals traders with EU supply chains must screen against both UK and EU lists to ensure full compliance.
UN Security Council consolidated list
The UN Security Council Consolidated List forms the baseline that most national sanctions regimes build upon. All UN member states are legally obligated to implement these sanctions, making the UN list the most universally applicable. National lists typically add additional designations based on their own foreign policy objectives, meaning the UN list represents the minimum standard.
UK Sanctions List
The UK Sanctions List, published by the FCDO, is the single list of everyone designated under UK sanctions, since OFSI closed its separate Consolidated List in January 2026. OFSI still implements and enforces financial sanctions. UK-based professionals dealing with EU-connected parties should screen against the EU list too. FirmScreen covers all major lists in a single screening operation, so there are no separate data sources to manage.
How lists overlap and diverge
The major lists share many names, but each also contains people the others don't.
Common designations
UN-designated entities and individuals typically appear on all national lists, as member states are obligated to implement UN sanctions. Russia-related sanctions post-2022 saw significant alignment between US, EU, and UK lists, though with differences in scope and exemptions.
Jurisdiction-specific designations
OFAC maintains extensive country-based programmes (Iran, Cuba, North Korea, Syria) that may not be fully replicated in EU or UK lists. Conversely, the EU may designate individuals or entities that are not on OFAC's SDN list. This makes multi-list screening essential for any business with cross-border exposure.
Practical screening strategy
For most non-financial institutions, screening against all four major list families (OFAC, EU, UN, UK) provides comprehensive coverage. FirmScreen aggregates these lists into a single screening operation, ensuring that a single name check covers all relevant designations. For guidance on configuring your screening approach, see our article on fuzzy name matching.