Compliance Blog

Written by Shari R. Pogach, Regulatory Paralegal

Earlier this month, the Department of Treasury’s (Treasury) Office of Foreign Assets Control (OFAC) announced the consolidation of all of its non-Specially Designated National (SDN) lists into one set of data files now known as the “ Consolidated Sanctions List.”  The consolidated files comply with all of OFAC’s existing data standards and include all of the following lists:

Non-SDN Palestinian Legislative Council (NS-PLC),

Part 561,

Non-SDN Iran Sanctions Act (NS-ISA),

Foreign Sanctions Evaders, (FSE List), and

Sectoral Sanctions Identifications, (SSI).

The consolidation upgrade was done to reduce the number of list-related files needed to be downloaded so as to maintain an automated sanctions screening program. When appropriate, OFAC also will add any new data associated with any sanctions list created where the required action of a U.S. person does not necessarily entail blocking to the consolidated data files.  OFAC’s changes are meant to ensure that all of the sanctions list records are included in its Sanctions List Search tool.  This tool allows users to search for a name on the SDN lists and the consolidated list.

In approximately six months, OFAC will stop issuing independent files for the FSE, SSI and NS-PLC lists.  During this transition period OFAC will still produce the data both on the individual lists and the consolidated list.  And, OFAC will continue to provide and update .pdf and .txt versions of the FSE, SSI, NS-ISA, NS-PLC and Part 561 lists and their respective archive of changes files.  These file formats will continue to be available even after the transition period.

Additional administrative technical information concerning the non-SDN list data is also available in the Treasury announcement.  And, here are related FAQs for additional information on algorithms, scoring and other technical details regarding Sanctions List Search.​

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​​​NCUA Board Actions. Yesterday, the NCUA Board issued two proposed rules.  The first would implement 2014 statutory changes to flood insurance measures affected by the Biggert-Waters Flood Insurance Act.  The second updates and technically revises the agency’s rules on corporate credit unions.  In addition, NCUA staff told the NCUA Board there will be no share insurance premium assessment for 2014.  There will soon be a NAFCU blog post breaking down the flood insurance proposal, so stay tuned!