In the past, banks were burdened with having to monitor updates to the SDN (Specially Designated Nationals) as well as the non-SDN sanctioned listings. Many have asked “Why are there so many different listings? Why not have a consolidated set of listings in a single file?” The Office of Foreign Assets Control has now made it easier for banks to comply with sanction screening requirements by distributing a consolidated listing of non-SDN entities. The non-SDN sanctions lists include the Palestinian Legislative Council List (“NS-PLC List”), the Non-SDN Iran Sanctions Act List ("NS-ISA List"), the Foreign Sanctions Evaders List ("FSE List"), and the Sectoral Sanctions Identifications List ("SSI List"). The lists are now available in a consolidated set of data files which can be found on the US Treasury OFAC website (the Consolidated Sanctions List).
While each of the non-SDN lists are still available in the individual list format, the consolidated listing makes it more convenient for Banks to comply with sanction screening requirements by having one data file that is inclusive of all non-SDN entities. This mitigates the need for Banks to monitor updates to multiple non-SDN listings and to further ensure that the OFAC interdiction software used is updated with each individual non-SDN listing. Thus, this further reduces the risk of the Bank’s non-compliance with sanction screening requirements, since banks no longer have to track updates to the multiple non-SDN listings.
If you haven’t already done so, contact your OFAC interdiction software service provider and discuss the new consolidated listings. The consolidated listings are now available in multiple file formats
Please refer to the following website for more information on the consolidated listing:http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/consolidated.aspx
Senior Manager - BSA/AML
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