The Clinton List (OFAC): What It Is and How to Check It
Where the name comes from, what the SDN list is and how to tell a name match from the person you are looking for.
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The Clinton List is the name used in Latin America for the Specially Designated Nationals and Blocked Persons (SDN) list, published by the Office of Foreign Assets Control (OFAC) of the US Treasury. The nickname comes from Executive Order 12978, signed by President Clinton in 1995 against Colombian drug traffickers. It is free to search in OFAC's Sanctions List Search.
Where the Name Comes From
Executive Order 12978
Signed on 21 October 1995.
It blocked the property under US jurisdiction of four principal leaders of the Cali cartel and allowed the Treasury to designate the people and companies that helped them. That is why the list became known by the name of the president who signed it.
The [SDNT] tag
Specially Designated Narcotics Traffickers.
The names designated under that order are incorporated into OFAC's SDN list with the programme tag [SDNT]. Those designated under the Foreign Narcotics Kingpin Designation Act carry the tag [SDNTK], to tell the two programmes apart.
Much more than drug trafficking
The SDN list today.
When people say Clinton List they usually mean the whole SDN list, which covers many OFAC programmes: individuals and companies owned or controlled by, or acting for, targeted countries, as well as terrorists and narcotics traffickers.
SDN List and Non-SDN Lists
OFAC publishes the SDN list and, separately, a consolidated file of other sanctions lists. Their effect is not the same.
| SDN list | Consolidated non-SDN lists | |
|---|---|---|
| Full name | Specially Designated Nationals and Blocked Persons | Other OFAC sanctions lists, such as Foreign Sanctions Evaders (FSE) and Sectoral Sanctions Identifications (SSI) |
| Effect for US persons | Their assets are blocked and US persons are generally prohibited from dealing with them | No obligation to block property, unless the name is also on the SDN list, but other prohibitions and restrictions apply |
| Where the Clinton List fits | Here, with the [SDNT] tag | Not here |
| Where to search it | Sanctions List Search | Sanctions List Search |
How to Check the Clinton List, Step by Step
- Open Sanctions List Search at sanctionssearch.ofac.treas.gov, OFAC's free tool. It searches the SDN list and every other sanctions list OFAC administers.
- Type the full name as it appears on the identity document. The tool tolerates some misspellings and returns close matches according to the Minimum Name Score you set; OFAC does not recommend any particular value.
- Open each result and read the programme, the addresses, the dates of birth and the identification numbers that OFAC published.
- Keep a record of the date, the name you searched and what you found, including when you found nothing: a clean result is also evidence.
OFAC itself warns that using Sanctions List Search is not a substitute for appropriate due diligence.
A Name Match Is Not an Identity Match
Common names produce results for people who have nothing to do with the list. OFAC calls them false hits and asks you to investigate before deciding.
Compare the quality of the match
Is it an exact name match or only a close one? Does your customer live in the same area as the listed person?
Check the identifiers
Date of birth, nationality, identity or tax numbers and addresses. A different identifier carries more weight than a similar name.
Document the decision
Discard or confirm under your compliance procedures, with the reason. If the doubt remains, escalate it: OFAC offers its hotline to verify a potential match.
Why Companies Outside the United States Check It
- All US persons must comply with OFAC sanctions: US citizens and permanent residents wherever they are, everyone within the United States, and US incorporated entities and their foreign branches. Many of your banks and business partners are among them.
- Non-US persons are prohibited from causing US persons to violate sanctions and from engaging in conduct that evades them.
- What your own regulator requires depends on each country's rules. Check your local obligations with your compliance officer or adviser.
The Clinton List, in COX
COX checks the OFAC SDN list and the consolidated non-SDN lists against its own copies of OFAC's official files and records the edition consulted. It compares the identification numbers OFAC publishes, every match is discarded or confirmed with a reason, and the PDF report states which lists were searched.
Restrictive list screeningFrequently Asked Questions
This guide is for informational purposes only and does not constitute legal advice. It summarises public information from OFAC without replacing it: confirm the scope of the sanctions and your obligations in OFAC's official publications, with your regulator or with an adviser.
Check Every Counterparty, and Keep the Evidence
OFAC, the United Nations, the European Union and local lists in one search, with the result on file.
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