
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
How does landing on the SDN list cut off a company from global finance?
Timeline for Specially Designated Nationals (SDN)
Mentioned in: Iran sanctions the register can't find
Iran Conflict 2026Mentioned in: GAESA was designated first, on 7 May
Cuba DispatchMentioned in: OFAC blocks 28 tankers and Bank Markazi
European Oil MarketsMentioned in: OFAC opens an all-programmes delisting portal
European Oil MarketsBackground
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.
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.
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 .
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.