The Clinton List (Lista Clinton): what it is and how to check it today
"Lista Clinton" is the popular Spanish name for the people and companies OFAC designates under Executive Order 12978, signed by President Clinton on 21 October 1995 to block the assets of significant foreign narcotics traffickers centered in Colombia (Executive Order 12978). There is no separate list to download. These designations sit on OFAC's SDN list under the program tag [SDNT], so checking the Clinton List means checking the SDN list (OFAC program tags).
Where the name comes from
Executive Order 12978 declared a national emergency over the actions of "significant foreign narcotics traffickers centered in Colombia" and ordered their property blocked, along with that of anyone found to materially assist them or to be owned, controlled by or acting for them (Executive Order 12978). Because the order carries President Clinton's signature, the resulting designations became widely known as "la Lista Clinton". The nickname does not appear in the order or on OFAC's program page.
OFAC lists the order on its counter narcotics sanctions page as "Blocking Assets and Prohibiting Transactions With Significant Narcotics Traffickers", effective 22 October 1995 (Counter Narcotics Trafficking Sanctions).
The three narcotics programs on the SDN list today
Executive Order 12978 is one of three narcotics authorities OFAC administers. Each has its own tag on the SDN list (OFAC program tags):
| Tag | Authority | Common name |
|---|---|---|
| SDNT | Narcotics Trafficking Sanctions Regulations, under Executive Order 12978 | The Clinton List |
| SDNTK | Foreign Narcotics Kingpin Sanctions Regulations, under the Kingpin Act | The Kingpin list |
| ILLICIT-DRUGS-EO14059 | Executive Order 14059 of 15 December 2021, on the global illicit drug trade |
When people say a company is "on the Clinton List", they usually mean any of these narcotics designations, not only SDNT. A complete check covers all three, which happens automatically when you screen the whole SDN list.
How to check a name against it today
- Search the full SDN list, not a copy of the Clinton List circulated in a spreadsheet. Old copies miss new designations and still show people who have since been removed.
- Look at the program tag on any candidate. SDNT, SDNTK or ILLICIT-DRUGS-EO14059 means a narcotics designation.
- Compare identifiers before concluding: full name, date of birth, nationality, cédula or passport number, address. OFAC's search scores name similarity only (OFAC FAQ 247), so a high score on a common name is a candidate to review, not a match.
- Keep a record of the check, with the date and the list publication you searched. That is the evidence a bank or auditor will ask for.
What a match means for a U.S. business
For a U.S. person, an SDN listing under any of these tags means the party's property must be blocked and dealings are prohibited. If you hold funds or property for a matched party, the reporting deadlines in what to do on a true match apply. If the candidate turns out to be a different person, write down why and keep it, as described in how to clear an OFAC false positive.
Check a name now
This is screening data, not legal advice. Search the SDN and Consolidated lists for free, including every narcotics designation, and see the program tag on each candidate.