OFAC is the single most consequential sanctions authority in the world, not because its legal powers are unusual but because of the currency. Most international trade settles in dollars, and dollar clearing runs through US financial institutions, which brings an enormous volume of transactions between non-US parties within OFAC’s reach.
What it publishes
The SDN List is the primary instrument, published in several machine-readable formats through the Sanctions List Service and updated as designations are made. Alongside it sit the Consolidated Sanctions List of non-SDN restrictions, a large corpus of programme-specific FAQs, general licences, and the advisories that supply most of the red-flag indicators used on this site.
Enforcement information is published as it is issued, with a penalty notice or enforcement release for each action setting out the conduct, the determination on egregiousness and self- disclosure, and the amount.
How its penalties work
Penalties are calculated per apparent violation against a statutory maximum, which is why a case involving thousands of small transactions can produce a figure unrelated to the value transferred or the profit made. Two determinations dominate the arithmetic: whether the conduct was voluntarily self-disclosed, and whether it was egregious. The difference between the best and worst combination of those two is roughly an order of magnitude.
The 50 percent rule
OFAC’s guidance that entities owned fifty per cent or more in aggregate by blocked persons are themselves blocked, whether or not named, is the single most consequential piece of interpretive guidance it has published, and it is why so much of this site concerns corporate ownership.