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SDN Designations Increase over 150% since 2015!

SDN Designations Increase over 150% since 2015!

With the changing of the POTUS guard, it is an appropriate time to check on the State of OFAC sanctions SDN designations since just before the last time the changing of the guard occurred. The following charts are from June 2015 and January 2021 respectively, and they show OFAC SDN designations increased 150%! (Please see: http://ofacanalyzer.com/rptListTotals.aspx).

SourceDescriptionUpdated On# Records
June 2015
OFAC(SDN) Specially Designated Nationals List06/04/1525,306
(OFCL) Consolidated List05/21/15416
BISBIS Denied Persons/Unverified List05/14/15874
FBIMost Wanted Terrorist List09/12/1442
Canada(OSFI)11/25/143,527
EuropeHM Treasury Sanction List05/20/157,838
European Union Sanction List02/21/1513,607
UNUnited Nations 1267 List09/12/142,336
SourceDescriptionUpdated On# Records
January 2021
OFAC(SDN) Specially Designated Nationals List01/19/2138,071
(OFCL) Consolidated List03/18/191,976
BISBIS Denied Persons/Unverified List/Entity List05/25/204,654
Canada(OSFI)09/30/201,524
EuropeHM Treasury Sanction List01/21/2110,736
European Union Sanction List03/19/1910,950
UNUnited Nations 1267 List03/16/206,31

This 2021 blog (as opposed to prior current event blogs at: https://thesanctionsgeek.com/blog/) will focus on practical challenges businesses face in complying with the ever dynamic sanctions laws given this uptick in designations. The increase does not appear to be an aberration of the Trump administration. Already with newly installed President Joe Biden talking tough via phone with Vladimir Putin and exclaiming the POTUS will have no reason to hold summits with Kim Jung Un unless North Korea denuclearizes first, the state of continued OFAC designations promises to be alive and well for the foreseeable future.

Crafting a proper set of policies and procedures to comply with sanctions laws will be mission critical, not to mention the proper selection of screening software, the proper resolution of potential matches, the ability to impose transaction stops in a timely manner as well as dealing with the new OFAC reporting requirements.