OFAC's non-SDN lists: SSI, FSE, CAPTA, NS-MBS, NS-CMIC and NS-PLC explained
OFAC keeps six sanctions lists outside the SDN list: the Sectoral Sanctions Identifications (SSI) list, the Foreign Sanctions Evaders (FSE) list, the CAPTA list, the Non-SDN Menu-Based Sanctions (NS-MBS) list, the NS-CMIC list and the NS-PLC list (Other OFAC Sanctions Lists). Each carries narrower restrictions than SDN blocking, and OFAC states for several of them that they are not part of the SDN list. All of them ship together in the Consolidated Sanctions List data files, so a check that only covers the SDN list misses them.
How these lists differ from the SDN list
A party on the SDN list is blocked: its property in U.S. hands is frozen and U.S. persons generally may not deal with it. The non-SDN lists exist because some sanctions stop short of that. OFAC describes the NS-MBS list, for example, as covering sanctions that "are less than full blocking sanctions" and notes that when full blocking applies, the person goes on the SDN list instead (Other OFAC Sanctions Lists).
The practical difference is what you must do on a match. An SDN match means blocking and reporting (31 CFR 501.603). A non-SDN match means checking which specific restriction applies to that entry and whether your transaction touches it.
The six lists
| List | Who is on it | What it restricts |
|---|---|---|
| SSI | Persons operating in sectors of the Russian economy identified under Executive Order 13662 | The prohibitions in the directive listed against each entry |
| FSE | Foreign persons found to have violated or evaded U.S. sanctions on Iran, under Executive Order 13608 | Transactions by U.S. persons or within the United States involving them |
| CAPTA | Foreign financial institutions | Opening or maintaining a correspondent or payable-through account, or strict conditions on one |
| NS-MBS | Persons subject to sanctions short of full blocking | The specific measures enumerated on each record |
| NS-CMIC | Companies named under the Chinese military-industrial complex securities order | The securities-related measures that order describes |
| NS-PLC | Members of the Palestinian Legislative Council elected on the slate of Hamas or another listed terrorist group | Lets U.S. financial institutions reject transactions with them |
Every row above comes from OFAC's own description of each list (Other OFAC Sanctions Lists).
Notes worth knowing before you screen
- The FSE list is empty today. OFAC removed the last name on 18 December 2025 and says new names may be added at any time (Other OFAC Sanctions Lists). An empty list is still a list you screen, because a future designation will land there.
- The same party can be on both. OFAC notes that individuals and companies on the SSI and FSE lists may also appear on the SDN list. Treat the SDN listing as the controlling one.
- The search tool labels them. In OFAC's Sanctions List Search, these entries show "Non-SDN" as the list type, with program tags such as "FSE-", "CAATSA - RUSSIA" or "CMIC-EO" (Other OFAC Sanctions Lists).
- The CAPTA list is for banks first. It lists foreign financial institutions and the account restrictions on them, and it does not include institutions already on the SDN list.
Where the data comes from
OFAC publishes each list as a PDF on its page, but the machine-readable versions of all the non-SDN lists sit in one place: the Consolidated Sanctions List files on the Sanctions List Service (Consolidated Sanctions List, Sanctions List Service). If you screen from files, download the SDN file and the Consolidated file on every publication. If you screen by search, make sure the tool you use searches both. OFAC's own Sanctions List Search covers the SDN list and its other sanctions lists (Sanctions List Search).
Why a small business screens both
Most small businesses will never touch a CAPTA bank or an NS-CMIC security. The reason to include the Consolidated list anyway is cost: it adds a small number of entries to every check, and leaving it out means a record that only proves you checked part of OFAC's lists. When an auditor or a lender asks what you screened against, "SDN and Consolidated, publication dated X" is a complete answer. "SDN only" invites a follow-up question.
If you export as well, the Commerce and State lists are a separate set again, consolidated by trade.gov. Our guide to SDN, Consolidated and the Consolidated Screening List explains which of the three you need, and What is OFAC covers the basics.
Check a name against both lists
This is screening data, not legal advice. Run a free check against the SDN and Consolidated lists and see which list and program tag any candidate comes from.