SDN List Data Specification Notice: Preface re: Blocking and Unblocking

Date issued: Jan. 05 2023

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (952 words)

Notes:

1) ACTUAL AND CONSTRUCTIVE NOTICE FOR “EFFECTIVE DATE” PURPOSES

The preface to this data specifications document, with language that overlaps with the prefaces to the actual text versions of the full SDN list (See e.g. https://www.treasury.gov/ofac/downloads/sdnlist.txt and lists of changes to the SDN list (https://www.treasury.gov/ofac/downloads/sdnnew19.txt), specify two important things that are not otherwise contained in OFAC's regulations.

First, OFAC characterizes the SDN list as a "reference tool providing actual notice of actions by OFAC with respect to Specially Designated Nationals and other entities whose property is blocked." OFAC says that the changes to the SDN list may "appear here prior to their publication in the Federal Register," but in practice this is almost always the case. OFAC appears to characterize electronic changes to the SDN list as providing "actual notice" of the changes, whether or...