OFAC sanctions programs explained
OFAC runs more than 30 sanctions programs, each built around a specific threat or a specific country.
TL;DR
TL;DR: OFAC sanctions programs are the individual country-specific and thematic programs that OFAC administers. Each program targets a specific threat such as terrorism, weapons proliferation, human rights abuse, or cyber activity.
How the programs work
Each program has its own legal authority and its own set of designated persons and entities, which appear on the SDN List. Blocking is the core tool: a designated party's assets are frozen and transactions with them are prohibited. The 50 Percent Rule extends blocking to entities that are 50 percent or more owned by a blocked person.
Why this matters for payments
A counterparty listed under any program triggers a BLOCK decision, regardless of which program it falls under. A screen therefore checks all programs at once, not one at a time. Missing a single program that lists your counterparty is the same as having no screen at all.
Examples of program types
- Country-specific programs targeting particular governments or regions.
- Thematic programs such as counterterrorism and counter-narcotics.
- Cyber and human rights programs focused on specific actors.