The SDN list restricts the relationship: US persons are generally prohibited from dealing with a listed party at all. The Entity List restricts the item: sending certain goods to a listed party needs a licence. Same name on both is possible, and the two do not cover each other.
| OFAC SDN | BIS Entity List | |
|---|---|---|
| Published by | US Treasury, Office of Foreign Assets Control | US Commerce, Bureau of Industry and Security |
| Instrument | Sanctions | Export controls |
| What is restricted | Dealing with the party; property and interests are blocked | Export, re-export or transfer of listed items to the party |
| Typical licence posture | Prohibited unless a general or specific licence applies | Licence required, frequently with a presumption of denial |
| Practical question | Should we be in any commercial relationship with them at all? | Are we about to send them something the entry covers? |
| Secondary exposure | Also relevant to ownership chains, where a listed party holds 50% or more | Applies to the named party, and the entry can extend to named fronts and aliases |
With an SDN hit, the decision is structural. Payment routing, contracts and future orders are all affected, and the question lands on ownership too: an entity owned half or more by a listed party can be treated as listed itself, even though its own name is nowhere on the list.
With an Entity List hit, the decision is item-level. The same customer may be entirely workable for unlisted products and closed for one specific product line. Teams that treat an Entity List hit the way they treat an SDN hit stop doing business they were allowed to do; teams that treat an SDN hit as an item question keep trading until something breaks.
Our free instant check covers OFAC, UK, EU, UN and US BIS lists in one pass and shows you which list each entry sits on.
No. Each regime binds different people and restricts different activity. A company can be clear in one jurisdiction and restricted in another, and a bank in a third country may still decline the payment on its own risk assessment.
Several official consolidated lists exist, but they are aggregations, and they update on their own schedules. Checking the aggregation is a reasonable first pass; when a name matches, confirm it against the issuing authority's own entry.