On August 5, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) published a notice of sanctions actions that both unblocked certain persons previously subject to U.S. sanctions and updated the entries of others whose property and interests in property remain blocked. These changes to the Specially Designated Nationals and Blocked Persons (SDN) List have immediate practical consequences for U.S. companies, financial institutions, and any organization engaged in cross-border transactions or sanctions screening.
According to OFAC, the property and interests in property of the specified persons subject to U.S. jurisdiction are unblocked and have been removed from the SDN List. As a result, transactions previously prohibited with those persons are no longer restricted under the relevant sanctions authorities. At the same time, OFAC updated the entries of other persons whose property and interests in property continue to be blocked, meaning that dealings with those parties remain prohibited absent an applicable license or exemption.
These simultaneous actions underscore the dynamic nature of the SDN List and the importance of maintaining current, accurate sanctions data within compliance programs. Screening systems that continue to rely on outdated SDN List information may generate two categories of risk: false positives, in which transactions with newly unblocked persons are unnecessarily delayed or rejected, and false negatives, in which transactions with persons whose entries have been revised are not properly identified and blocked.
Companies engaged in cross-border transactions or sanctions screening should promptly update their compliance systems and screening tools to reflect the revised SDN List entries. Recommended steps include refreshing screening databases with the latest OFAC data, reviewing pending and recently rejected transactions against the updated list, revisiting customer and counterparty due diligence records for any affected persons, and confirming that internal policies, procedures, and training materials reflect the current state of the SDN List.
Given the potential for civil and criminal liability associated with sanctions violations, organizations should also document their compliance actions taken in response to these updates and consider whether any prior blocked property reports require corresponding adjustments.
This alert is provided for general informational purposes only and does not constitute legal advice. Clients should seek tailored counsel regarding their specific sanctions compliance obligations.