Disbursement Controls Resource · Reference Tables

OFAC Sanctions Reference

Quick-reference data on OFAC penalty exposure and the component lists that make up the Consolidated Sanctions List. Screen every vendor and payment against the SDN List at minimum; consult the others based on counterparty type and transaction structure.

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$377K+

Statutory maximum per violation, adjusted for inflation (IEEPA-based programs)

2×

Transaction value — applied when it exceeds the base figure, which is common for large payments

20 yrs

Maximum criminal imprisonment for willful violations, plus fines up to $1M per violation

Program / Item	What It Covers	Why AP Should Care
SDN List	Specially Designated Nationals and Blocked Persons — the primary enforcement list. Assets are blocked and transactions prohibited for all U.S. persons. Updated multiple times weekly.	The mandatory baseline screen for every vendor and every payment, every time.
Sectoral Sanctions Identifications (SSI) List	Entities operating in designated sectors of the Russian economy.	Not a full block — transactional prohibitions apply to specific debt and equity activity. Review vendor payment terms and financing structures.
Non-SDN Chinese Military-Industrial Complex (NS-CMIC) List	Chinese companies with connections to China's military-industrial complex, subject to U.S. investment and securities restrictions.	Relevant mainly for equity transactions or dealings with Chinese defense and surveillance-technology entities.
Correspondent Account / Payable-Through Account (CAPTA) List	Foreign financial institutions subject to restrictions or prohibitions on correspondent account relationships with U.S. banks.	Matters whenever a vendor routes payments through a foreign financial institution on this list.
Foreign Sanctions Evaders (FSE) List	Foreign persons who facilitated deceptive transactions for sanctioned parties or violated U.S. Iran or Russia sanctions.	Emptied as of December 2025, but new designations can be added at any time — screen anyway.
Non-SDN Menu-Based Sanctions (NS-MBS) List	Persons subject to targeted sanctions short of full blocking, with specific transactional prohibitions defined record-by-record.	Requires reviewing the specific restriction tied to each listed entity before proceeding.

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.