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OFAC Releases New UN-Recommended Sanctions List Format

The Treasury Department’s Office of Foreign Assets Control released on Jan. 5 a new format for the agency’s Specially Designated Nationals list (here). The change complies with a United Nations plan to create a universally accessible and understandable sanctions list, designed to better enforce sanctions designations, said OFAC. The U.S. is the first UN member to put in place this “advanced sanctions data model,” the agency said. The new format includes the following features, among others, according to OFAC:

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  • Provides a great deal of new metadata including specific labels for name parts that go beyond the standard, “Last name, First name” style of current sanctions lists. The advanced format now allows for unique name parts to be used, labeled and properly ordered based on the nomenclature rules of a specific culture, language, or region.
  • Supports language scripts beyond the standard Latin script used in many sanctions lists. It is now possible for sanctions targets to be provided to users in their original script (e.g., Arabic) and other non-Latin script translations. Treasury will provide a Latin script translation for all listed, non-Latin script sanctions targets.
  • Provides a data dictionary of all valid look-up values in the header of the file. Including a data dictionary with the underlying data makes it easier for list users to construct databases that contain identifiers and other information that match the data in OFAC’s systems. When new look-up values are introduced to a sanctions list, this data dictionary is automatically updated.
  • Introduces a flexible, “feature identifier” functionality that augments the normal identification look-up values that are currently available in the SDN List formats. Historically, the “remarks field” in the Treasury SDN list’s data format had been used for information that did not easily fit into existing fields and identifier categories. Using the advanced format, Treasury will now be able to provide easily-parsed, non-traditional identifier information.