The Office of Foreign Assets Control (OFAC) has published a significant update to the Specially Designated Nationals and Blocked Persons (SDN) List as part of its ongoing sanctions-modernization initiative. The update involves three categories of changes:

1. 84 removals — individuals and entities removed from the SDN List
2. 22 enhanced entries — existing entries updated with improved identifying information
3. 18 duplicate consolidations — administrative deletions of duplicate entries

Each category has different compliance implications, and the distinction between a true delisting and an administrative consolidation is critical.

Treasury states that many of the 84 removals concern:

• Deceased persons — individuals who have died and are no longer treated as active sanctions targets
• Defunct entities — companies or organizations that no longer exist
• Older targets — persons or entities no longer treated as current U.S. national-security or foreign-policy priorities

A genuine removal means that the person or entity is no longer on the SDN List. Transactions with genuinely removed parties are no longer prohibited solely on the basis of the former SDN designation — subject to confirming that no other sanctions program, ownership rule, or export-control restriction applies.

Before treating a removal as permitting a transaction, compliance teams must verify:

1. No other SDN entry: Confirm that the removed party does not appear under a different name, alias, or identifier on the current SDN List
2. No other sanctions program: The SDN List is not the only source of U.S. sanctions restrictions. Confirm that the party is not subject to country-based sanctions (Iran, Russia, Cuba, North Korea, Syria, etc.) that apply regardless of SDN designation
3. No 50% rule application: OFAC's 50% rule provides that entities owned 50% or more by a sanctioned person are themselves blocked, even if not listed. Confirm that the removed party is not owned or controlled by a remaining SDN
4. No export control restrictions: EAR Entity List, Denied Persons List, and ITAR Debarred Parties List restrictions are separate from OFAC sanctions and are not affected by OFAC delistings
5. No secondary sanctions risk: For transactions involving non-U.S. parties, confirm that the removed designation does not implicate secondary sanctions provisions that could affect the non-U.S. counterparty

Screening databases must be updated promptly. A match against a removed entry that has not been deleted from the screening database will generate a false positive — potentially blocking a legitimate transaction. However, the update should be implemented carefully to ensure that the removal is genuine and not an administrative consolidation (see below).

OFAC has enhanced the identifying information for 22 existing SDN entries. These entries remain on the SDN List — the underlying designations are unchanged. The enhancements may include:

• Additional aliases or name variants
• Updated addresses or locations
• Additional identification documents (passport numbers, national ID numbers, tax identification numbers)
• Clarified entity structures or ownership information

Compliance implication: Enhanced entries may generate new matches in screening systems that previously did not flag the party. Compliance teams should review the 22 enhanced entries and assess whether any existing customer, counterparty, or transaction relationships are affected.

OFAC consolidated 18 duplicate entries — cases where the same person or entity appeared on the SDN List under multiple entries. The duplicate entries have been deleted, leaving a single consolidated entry for each target.

This is the most legally significant aspect of the update. OFAC explicitly states that duplicate-entry deletions are administrative only: the underlying persons and property remain sanctioned under the retained entries, and related assets remain blocked.

A compliance team that treats a deleted duplicate entry as a genuine delisting — and permits a transaction on that basis — is making a potentially serious compliance error. The party is still on the SDN List; only the redundant entry has been removed.

When reviewing the list of 84 removals, compliance teams should:

1. Cross-reference the removed entry against the current SDN List — if the same person or entity appears under a different entry number or name variant, the removal is a consolidation, not a true delisting
2. Review OFAC's accompanying documentation — OFAC typically identifies which removals are consolidations in the Federal Register notice or accompanying press materials
3. Contact OFAC's compliance hotline if there is uncertainty about whether a specific removal is genuine or administrative

1. Refresh screening databases — update all SDN screening systems with the current list
2. Identify affected matches — run a comparison between the previous and current SDN List to identify all changed entries
3. Categorize changes — for each changed entry, determine whether it is a genuine removal, an enhanced entry, or a duplicate consolidation
4. Re-screen existing relationships — re-screen current customers, counterparties, and transactions against the updated list

1. Review historical matches — for each of the 84 removed entries, review whether any prior transaction was blocked or rejected solely because of that designation; if so, assess whether the transaction may now proceed
2. Update internal watchlists — if the compliance program maintains internal watchlists derived from the SDN List, update them to reflect the changes
3. Document the review — maintain records of the review process, the categorization of each changed entry, and the compliance decisions made

1. Monitor OFAC updates — OFAC updates the SDN List frequently; compliance programs should have automated processes for receiving and processing updates
2. Coordinate with screening vendors — confirm that third-party screening vendors have updated their databases and that the update has been validated

Turkish banks with U.S. dollar correspondent relationships are subject to OFAC jurisdiction for any U.S. dollar transaction. The SDN List update requires:

• Immediate database refresh in all OFAC screening systems
• Re-screening of any customer or counterparty that matched a removed or enhanced entry
• Careful analysis of whether any removed entry is a genuine delisting or a duplicate consolidation

Turkish companies engaged in trade with U.S. counterparties or using U.S. financial institutions for trade finance must ensure that their OFAC screening programs reflect the updated SDN List. A transaction that was previously blocked due to an SDN match may now be permissible — but only after confirming that the removal is genuine and that no other restriction applies.

Turkish companies with U.S. subsidiaries or operations are directly subject to OFAC regulations. Their U.S. compliance programs must be updated immediately to reflect the SDN List changes.

This article is based on publicly available OFAC announcements. It does not constitute legal or compliance advice. Companies subject to OFAC regulations should consult qualified sanctions counsel and ensure that their compliance programs are updated promptly.