International Financial Law Prof Blog

Editor: William Byrnes
Texas A&M University
School of Law

Thursday, January 15, 2015

Release of New, Advanced Format for the Specially Designated and Blocked Persons List.

OFACOFAC released a new format for the Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons (SDN) List

This new sanctions list format was jointly developed by the United Nations (U.N.) and the Wolfsberg Group of International Banks in an effort to create a universal sanctions list format that can be efficiently used by governments worldwide and enhances sanctions compliance.  The new format incorporates a variety of features that ensure maximum flexibility for sanctions list creators, while also limiting the need for future changes to the underlying data specification due to the standard’s adaptability.

Some of the new capabilities associated with the advanced sanctions list format include:

  • The advanced format provides a great deal of new metadata including specific labels for name parts that go beyond the standard, “Last name, First name” style of current sanctions lists.  The advanced format now allows for unique name parts to be used, labeled and properly ordered based on the nomenclature rules of a specific culture, language, or region.
  • The new format now supports language scripts beyond the standard Latin script used in many sanctions lists.  It is now possible for sanctions targets to be provided to users in their original script (e.g., Arabic) and other non-Latin script translations.  The Treasury Department will provide a Latin script translation for all listed, non-Latin script sanctions targets.
  • The advanced list format provides a data dictionary of all valid look-up values in the header of the file.  Including a data dictionary with the underlying data makes it easier for list users to construct databases that contain identifiers and other information that match the data in OFAC’s systems.  When new look-up values are introduced to a sanctions list, this data dictionary is automatically updated.
  • This new format introduces a flexible, “feature identifier” functionality that augments the normal identification look-up values that are currently available in the SDN List formats.  Historically, the “remarks field” in the Treasury SDN list’s data format had been used for information that did not easily fit into existing fields and identifier categories.  Using the advanced format, Treasury will now be able to provide easily-parsed, non-traditional identifier information. 

The United States is the first U.N. member state to implement this advanced sanctions data model.  In an effort to ensure a greater level of global sanctions compliance the Treasury Department supports the new sanctions list model and appreciates the efforts of the U.N. and the Wolfsberg Group in their creation of a universal format.  

What is the new XML product that OFAC is offering?

OFAC is offering a new XML product that conforms to an advanced, UN-developed data standard.  For more information on this new format please visit the following page: SDN XML File in Sanctions Data Model format.

Will this new XML format replace the existing XML?  Will I need to switch to this new XML format in the future?

No, this new XML file will not replace the existing SDN.xml file which will remain in production.  OFAC will continue to support all of its current data offerings even after the new XML standard goes into production.   This includes the continual support of its legacy files (the fixed-width, .CSV, .PIP, and .DEL files) for the foreseeable future.

Specially Designated Nationals List - Advanced Sanctions Data Model​
SDN XML File in Advanced Sanctions Data Model format (70MB)
SDN XML File in Advanced Sanctions Data Model format (Compressed Zip File)​​​​
Schema for SDN XML File in Advanced Sanctions Data Model format
Explanatory Documentation for Advanced Sanctions Data Model format​
Frequently Asked Questions About the Advanced Sanctions Data Model of the SDN list​

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