OFAC vs UN vs EU Sanctions Lists: What's the Difference?

There is no single global sanctions list. Different governments and international organizations maintain their own lists, each with different scope, coverage, and legal authority. If you are building a compliance system, knowing which lists to screen against and why is essential.

This article covers the four major sanctions lists that most businesses need to worry about, what each one contains, and how they overlap.

OFAC SDN List (United States)

The Specially Designated Nationals and Blocked Persons List is published by the U.S. Treasury Department's Office of Foreign Assets Control. It is the most widely used sanctions list in the world.

• Entries: 18,700+ individuals, companies, vessels, and aircraft
• Updated: Multiple times per week, sometimes daily
• Applies to: All U.S. persons, companies operating in the U.S., and anyone transacting in U.S. dollars
• Scope: Covers entities tied to terrorism, narcotics trafficking, weapons proliferation, human rights abuses, and country-specific programs (Russia, Iran, North Korea, etc.)

The SDN list is the most important list for any business with exposure to the U.S. financial system. If you process payments in USD or have U.S. customers, you need to screen against this list. The penalties for violations are severe: up to $330,000 per violation for negligent infractions and up to $20 million for willful violations.

UN Security Council Consolidated List

The United Nations maintains a consolidated list of individuals and entities subject to sanctions imposed by the UN Security Council.

• Entries: 1,000+ individuals and entities
• Updated: As new resolutions are adopted
• Applies to: All UN member states (193 countries)
• Scope: Primarily focused on terrorism (Al-Qaeda, ISIL/Da'esh), North Korea's nuclear program, and specific conflict zones

The UN list is smaller than the OFAC list because it only includes entities sanctioned through Security Council resolutions, which require agreement among the five permanent members (U.S., UK, France, Russia, China). Many entries on the UN list also appear on the OFAC SDN list, but not all.

Because UN sanctions are binding on all member states, this list is relevant regardless of where your business is located. If you are operating anywhere in the world, you should screen against the UN list.

EU Consolidated List

The European Union maintains its own consolidated financial sanctions list, implemented through EU Council regulations.

• Entries: 5,800+ individuals and entities
• Updated: As new regulations are adopted, typically several times per month
• Applies to: All EU member states, EU citizens worldwide, and entities incorporated in the EU
• Scope: Covers terrorism, Russia/Ukraine conflict, Belarus, Myanmar, and various country-specific regimes

The EU list has grown significantly since 2022 due to sanctions related to Russia's invasion of Ukraine. It includes many Russian oligarchs, government officials, and companies that may not appear on the OFAC list, and vice versa.

If your business operates in Europe, serves European customers, or processes transactions in euros, you need to screen against the EU list.

UK HM Treasury / OFSI List

Since Brexit, the United Kingdom maintains its own independent sanctions list through the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury.

• Entries: 5,100+ individuals and entities
• Updated: Regularly, as new designations are made
• Applies to: All persons in the UK, UK nationals worldwide, and entities incorporated in the UK
• Scope: Similar to the EU list but with some UK-specific designations, particularly related to Russia, Iran, and human rights

The UK list largely mirrors the EU list but has diverged in some areas since Brexit. There are entities on the UK list that are not on the EU list, and vice versa. If your business has any connection to the UK market, you should include this list in your screening.

How the lists overlap

There is significant overlap between these lists, but they are not identical. Here is how to think about it:

• Most UN-sanctioned entities appear on all four lists, because UN sanctions are binding on member states.
• The U.S. has many sanctions that are unilateral (not adopted by the UN), so the OFAC list contains thousands of entries not found on other lists.
• The EU and UK lists share most entries but have diverged since Brexit.
• Some entities are sanctioned by the EU and UK but not by the U.S., particularly related to domestic European policy concerns.

This is why screening against a single list is not enough for most businesses. An entity might be sanctioned by the EU but not by OFAC, and if you serve European customers, you need to catch that.

Which lists should you screen against?

The answer depends on where you operate and who your customers are:

In practice, most fintechs that are serious about compliance screen against all four lists. The cost difference between screening one list and four lists is negligible with a modern API, and the risk of missing a sanctioned entity on a list you did not check is not worth the savings.

How Verifex handles multiple lists

Verifex screens against all four major lists in a single API call. You do not need to make separate requests for each list. When you submit a name, the engine checks it against OFAC SDN, UN Security Council, EU Consolidated List, and UK HM Treasury simultaneously, and the response tells you which list produced each match.

Lists are synced automatically from official government sources multiple times per day. OFAC is updated every 6 hours, UN and EU every 12 hours, and UK daily. You always screen against the latest data without having to manage list downloads yourself.