SDN list
OFAC's Specially Designated Nationals list; entities on it are blocked from the US financial system.
Last refreshed: 16 April 2026 · Appears in 1 active topic
Now Rosneft and Lukoil are back on the SDN list, who actually enforces it?
Timeline for SDN list
Mentioned in: Treasury kills $150M-a-day Russian oil waiver
Russia-Ukraine War 2026- What is the SDN list and what does it do to Russian oil?
- The SDN list bans US persons from transacting with listed entities. Because oil trades are dollar-denominated, SDN listings also create compliance pressure for non-US buyers. Rosneft and Lukoil were redesignated on 16 April 2026 after GL 134A expired.Source: Lowdown / OFAC
- What is General Licence 134A?
- GL 134A was an OFAC authorisation that gave companies a transitional period to wind down Russian energy transactions. It expired on 16 April 2026 without renewal, triggering the redesignation of Major Russian oil companies.Source: Lowdown / OFAC
- Can China and India still buy Russian oil after the SDN redesignations?
- They can, but settlements must avoid the US dollar and US correspondent Banks or risk secondary sanctions. The SDN listings push trades toward yuan or rupee settlement, adding cost and friction.
Background
The Specially Designated Nationals (SDN) list is maintained by the US Treasury's Office of Foreign Assets Control (OFAC). Any entity, individual, or vessel placed on the SDN list is effectively frozen out of the US financial system: US persons and companies are prohibited from transactions with them, and any assets within US jurisdiction are blocked. The list is a primary instrument of US economic coercion and has been central to the West's response to Russia's invasion of Ukraine. On 16 April 2026, OFAC redesignated Rosneft, Lukoil, and several other Russian energy companies onto the SDN list following the expiry of General Licence 134A, which had provided a transitional wind-down period.
OFAC publishes the SDN list and associated General Licences (GLs) that carve out specific permitted activities. GLs are time-limited and can be renewed, extended, or allowed to expire. When GL 134A lapsed without renewal on 16 April 2026, the extended transitional permissions for Russian crude energy transactions ended, triggering the wave of redesignations. Secondary sanctions can also penalise non-US entities that transact with SDN-listed parties if those transactions touch the US financial system.
The SDN list affects global energy markets beyond US persons: because most oil trades are dollar-denominated and cleared through US correspondent Banks, SDN listings create compliance obligations for Indian, Chinese, and other non-Western importers who wish to avoid being cut off from the US financial system. This is the mechanism by which the 16 April redesignations are expected to constrain Russian oil revenue even without direct US-Russia trade.
