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Specially Designated Nationals (SDN)
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Specially Designated Nationals (SDN)

OFAC's master blacklist of individuals, entities, and vessels barred from the US financial system.

Paperwork made public on 31 July revealed Cuba sanctions actually dated as far back as 7 May, including GAESA's addition to the Specially Designated Nationals list weeks before Washington let the designation become known.

Last refreshed: 4 August 2026 · Appears in 3 active topics

Key Question

How does landing on the SDN list cut off a company from global finance?

Timeline for Specially Designated Nationals (SDN)

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Background

The Specially Designated Nationals list is the enforcement instrument of the US Treasury's Office of Foreign Assets Control. Anyone or anything listed has its US-jurisdiction assets frozen, and US persons are barred from transacting with them; because most global trade clears through dollar correspondent banks, designation functions as exclusion from the world financial system rather than just the American one.

The list spans legally distinct programmes that can move independently of one another: Iran designations run under counterterrorism and nuclear authorities, Russia entries under Ukraine-related and CAATSA authorities, and Cuba entries now carry the [Cuba-EO] tag introduced by Executive Order 14404, which was formally numbered and given its savings clause, OFAC's Cuba General Licence 1, on 7 May 2026 . That day also produced the first individual designation under the new tag, a previously unprofiled mid-level intelligence officer rather than a senior official, signalling OFAC was starting at the operational-security tier and working upwards .

Each programme carries its own general-licence architecture, so a listed vessel or individual can sit on the blacklist under one programme while a separate wind-down licence briefly authorises specific transactions with it. Naval and financial enforcement do not always move together: sanctioned vessels have transited contested waters unchallenged even while blacklisted on paper, underscoring that the SDN list constrains banking access rather than physical movement.

Key Issues
Cuba blacklist gap

GAESA's listing predated its disclosure

Paperwork finally caught up with reality on 31 July: four notices in the Federal Register logged Cuba sanctions actually dated between 7 May and 23 June, weeks apart from when Washington had let each one become known. One showed GAESA, the military's business empire controlling an estimated 60 per cent of the island's hard-currency earnings, joining the SDN list back on 7 May, well before the public had heard about the port, banking and hotel-fund actions taken against its subsidiaries over the summer .

The disclosure gap sits within a wider pattern of accelerating additions. On 13 July the department designated ten more Cuban entities in a single day, its largest batch since 18 May, reaching the Ministry of Tourism for the first time and naming Antex for exporting labour Washington calls forced labour . Each addition freezes the listed party's US-jurisdiction assets and bars US persons from transacting with it, cutting it off from dollar-clearing banks regardless of where it actually operates.

Sanctions wave two

A second wave reached Cuba's ministries

Washington's second sanctions wave under Executive Order 14404 landed on 18 May, blocking 11 named Cuban officials and three bodies: the interior ministry, the national police and the intelligence directorate, including energy chief Vicente de la O Levy and Assembly head Juan Esteban Lazo Hernandez .

The same day, OFAC signed General Licence 134C and excluded Cuba from its protection, adding nine further Cuban officials to the blacklist and stranding any Russian oil cargo that had passed through Cuban logistics; one newly listed official sits in Cienfuegos, home to Cuba's main refinery, forcing traders to trace each cargo's full voyage rather than trust its paperwork .

Iran crypto freeze

A crypto freeze hit Iran twice over

US Treasury sanctioned Iran's four largest crypto exchanges on 2 June, including Nobitex, which had handled more than half of Iran's digital-asset inflows in 2025, freezing roughly $500 million under the Economic Fury campaign .

The designations cut two channels the SDN mechanism was built to sever: the Revolutionary Guard's toll revenue from the Strait of Hormuz and the Central Bank of Iran's only remaining dollar-buying route, both severed on the same days the rial recovered 1.7 per cent. It is the same legal instrument used against Cuba's GAESA and its ministries, applied here under counterterrorism rather than Cuba-specific authority.

Common Questions
Who is on the SDN list under EO 14404?
As of 7 May 2026, Ania Guillermina Lastres Morera is the first individual designated under the [Cuba-EO] tag. OFAC also updated existing GAESA and Moa Nickel SA SDN entries to layer [Cuba-EO] onto pre-existing [Cuba] designations.Source: OFAC SDN list
What was added to the OFAC SDN list on 14 July 2026?
OFAC designated more than 50 individuals, entities and vessels linked to Mohammad Hossein Shamkhani's Iranian shipping network, including around 28 vessels and crypto addresses tied to Bank Markazi, Iran's central bank.Source: OFAC recent-actions record, 14 Jul 2026
Why does SDN listing not always stop ships at sea?
Naval and financial enforcement are separate tracks. During the 2026 Hormuz crisis, CENTCOM allowed US-sanctioned Chinese tankers to transit the strait unchallenged even as OFAC maintained their SDN designations.Source: Lowdown
Which Cuban officials were added to the SDN list in 2026?
Ania Guillermina Lastres Morera was the first individual designated under EO 14404 on 7 May 2026. A second wave on 18 May named eleven officials plus MININT, PNR, and the DGI under the new [Cuba-EO] tag.Source: OFAC
Can a general licence override an SDN designation?
Yes, OFAC general licences can carve out specific transactions even for SDN-listed parties. GL 134C (May 2026) did exactly this for Russian crude cargoes in transit, though it explicitly excluded Cuba-flagged transactions.Source: OFAC
How many sanctions programmes does the SDN list cover?
Dozens, including separate programme tags for Iran, Russia, Cuba, North Korea, counter-narcotics (SDNTK), and cyber threats. Each carries its own licensing rules, so a party can be listed under one programme while a general licence temporarily authorises certain dealings.Source: OFAC
What does it mean to be on the OFAC SDN list?
Your US-jurisdiction assets are frozen and US persons are barred from doing business with you. Because most global trade clears through US banks, it effectively bars access to the dollar-denominated financial system worldwide.Source: OFAC
When were the first Economic Fury SDN designations issued?
OFAC added nine tankers to the SDN list on 15 April 2026 in the first Economic Fury action targeting the Shamkhani Iranian oil-smuggling network. Subsequent rounds have designated entities including CGSTL, Hengli network actors, and four Hong Kong shells.Source: OFAC SDN list
Can a ship removed from the SDN list go back to work immediately?
No. Even after delisting, ships face insurance blacklists, flag-state problems, crew reluctance, and charterer caution. De-sanctioning is administratively possible but commercially marginalised for years, even if technically legal.Source: Lowdown editorial knowledge
How effective is the SDN list at stopping sanctions evasion?
The SDN list is effective at blocking US dollar transactions and traditional banking, forcing evasion networks to use alternative payment systems, cryptocurrencies, or barter. However, determination and access to enough Shell companies can extend operational time.Source: Lowdown editorial knowledge
What is the [CUBA-EO] SDN tag?
[Cuba-EO] is the OFAC SDN list category tag for designations under Executive Order 14404, the 1 May 2026 Cuba personal-sanctions order. Ania Guillermina Lastres Morera was the first individual designated under the tag on 7 May 2026.Source: OFAC SDN list
How many Iranian tankers were sanctioned by OFAC in April 2026?
Nine tankers were added to the SDN list on 15 April 2026 as part of the action targeting the Shamkhani Iranian oil-smuggling network.Source: US Treasury OFAC
What happened to Cuba sanctions on 13 July 2026?
The State Department added ten Cuban entities under EO 14404, the largest single-day Cuba batch since 18 May. OFAC's same-day FAQ 1262 gave only GECOMEX and GEMAR a 30-day wind-down to 12 August; tourism operator MINTUR was Left without guidance.Source: OFAC / State Department
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