Disbursement Controls Resource · Reference Tables

OFAC Country & Program Sanctions Reference

Beyond list-based screening, OFAC sanctions also attach at the country and ownership level. A vendor can be unsanctioned by name and still be unpayable because of where it operates or who controls it.

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17,000+

Names currently on the SDN List across all OFAC sanctions programs

Countries under full U.S. trade and financial embargo: Cuba, Iran, North Korea

50%

Ownership threshold that blocks an unlisted entity if SDN-listed parties own it, individually or in aggregate

Program / Item	What It Covers	Why AP Should Care
Cuba, Iran, North Korea	Comprehensive embargo — virtually all transactions prohibited without an OFAC license.	Treat as unpayable absent a specific or general license. Don't rely on counterparty name screening alone — the country itself is the block.
Crimea, Donetsk, Luhansk regions (Ukraine)	Comprehensive-style restrictions under Russia-related executive orders, including bars on new investment and on imports from or exports to the covered regions.	Screen the vendor's region of operation, not only its name — registered address and service-delivery location both matter.
Syria	Comprehensive embargo formally lifted in 2025. Designated individuals, including former regime officials, remain sanctioned under separate authorities.	The country-level block is gone, but SDN List name screening still applies to specific Syrian counterparties.
Russia	Extensive targeted and sectoral sanctions — finance, energy, defense — rather than a single comprehensive embargo.	Transactions with non-designated Russian parties are often technically lawful but carry elevated banking, payment-routing, and compliance risk.
Belarus, Venezuela, Myanmar	Heavily targeted sanctions programs — serious but short of full embargoes.	Screen counterparties and review the specific program prohibitions before approving payment.
50 Percent Rule	Any entity owned 50% or more, individually or in aggregate, by one or more SDN-listed parties is automatically blocked — even if the entity never appears on a list itself.	Name-only screening misses this entirely. Beneficial-ownership verification is required for higher-risk or opaque vendor structures.

This reference is provided as an educational resource for accounts payable, treasury, and shared services professionals. It does not constitute legal, tax, or compliance advice. Figures and list contents change; verify against the official source before acting.