OFAC SDN List Growth Over Time: 2024 Statistics, Trends, and Analysis

Methodology

The designation counts on this page track the number of persons (individuals and entities) newly added to OFAC's Specially Designated Nationals and Blocked Persons (SDN) List each calendar year. Primary data comes from the Center for a New American Security (CNAS), which publishes annual "Sanctions by the Numbers" reviews compiled from OFAC press releases, Federal Register Notices, and Treasury announcements. CNAS has published this series continuously since the Obama administration and is the most cited independent source for year-on-year SDN designation trends.

One person here is one named individual or entity (corporation, bank, or vessel). One person can generate multiple SDN list entries if aliases are recorded separately. The figures on this page count unique persons designated, not total list entries or aliases.

Enforcement data comes from OFAC's published civil penalties page and from Miller & Chevalier's annual OFAC Year in Review, which compiles official enforcement releases. Delistings data comes from CNAS annual reviews. The 2025 CNAS "Sanctions by the Numbers" series is the source for the 2025 figure.

All figures cover calendar years. There are no estimates or projections in the data table; every row traces to a named primary or Tier-1 source.

Full data table

All designation counts from CNAS "Sanctions by the Numbers" annual series, compiled from OFAC press releases and Federal Register Notices.

Key findings

• The pre-2022 baseline was 815 persons per year. Between 2017 and 2021, OFAC averaged 815 new SDN designations annually (CNAS 2022 Year in Review). The 2019-2021 three-year window produced 2,305 total designations. That number looks almost quaint now.

• Russia's invasion tripled annual designations in a single year. In 2022, OFAC added 2,275 persons to the SDN list, up from 743 in 2021. Of those 2,275 designations, 1,698 were Russia-related (CNAS 2022 Year in Review). The invasion of Ukraine on February 24, 2022 is the cleanest single event driving any growth trend in this data.

• 2024 was the peak designation year on record. 3,135 persons were designated, a 25 percent increase over 2023. Russia-related sanctions accounted for 70 percent of all additions; 1,706 Russian persons were designated alongside 276 Chinese persons, the second-highest national count for the year. OFAC issued eight separate announcements of 100 or more additions in 2024 alone (Miller & Chevalier, OFAC Year in Review 2024).

• Delistings doubled in 2023 but don't offset additions. OFAC removed 422 persons from the SDN list in 2023, almost double the 218 delistings in 2022 (CNAS 2023 Year in Review). The net addition in 2023 was approximately 2,080 persons. Even with aggressive delisting activity, the list grows faster than it contracts.

• The Trump administration reversed course in 2025. New designations fell to 1,764 in 2025, a 44 percent drop from 2024. Of those, 442 were from the outgoing Biden administration's final weeks and 1,322 from the Trump administration (CNAS 2025 Year in Review). Thirty-eight Russia-related designations from the Biden era were also removed in 2025.

Year-over-year trends

From 2019 through 2021, designation volumes were remarkably flat: 785, 777, and 743 respectively. The variation between any two of those years was under 6 percent. This stability reflected a consistent but contained sanctions posture across both the end of the first Trump administration and Biden's first year.

February 2022 broke that pattern permanently. The 2022 total of 2,275 represented a 206 percent increase from 2021, driven almost entirely by Russia sanctions following the invasion of Ukraine. 1,698 of 2,275 additions that year were Russia-related, meaning non-Russia designations actually stayed in line with prior years.

Growth continued in 2023 (+10 percent, to 2,502) and accelerated in 2024 (+25 percent, to 3,135). The 2024 pace included sustained pressure on Russia's military-industrial base, its financial sector (including Gazprombank designations in November 2024), and third-country networks in China, Türkiye, and the UAE facilitating sanctions evasion. OFAC's stated goal was to disrupt supply chains feeding Russia's military, not just freeze Russian assets.

The cumulative 2022-2024 three-year total is 7,912 designations. The comparable 2019-2021 window was 2,305. That's a 243 percent increase over a like period, driven entirely by one geopolitical event.

The 2025 reversal (1,764 designations) reflects the Trump administration's deliberate pullback from Russia sanctions and a pivot toward Iran as the primary sanctions priority. Whether 2025 marks the start of a structural decline or a one-year interruption is unclear; the Iran-focused posture is already generating new designation volumes in its own right.

What this means for compliance teams

The fourfold increase in annual SDN designations since 2021 has one direct operational consequence: sanctions screening programs built for a world of 743 additions per year are inadequate for one producing 3,135. Firms that rely on overnight batch screening runs face exposure windows of 24 hours or more when a major OFAC action drops 100 or more names simultaneously, which happened eight times in 2024.

The geography of the list has also shifted. Pre-2022 OFAC enforcement prioritized Iran and Venezuela with a reasonably predictable set of jurisdictions and industries. The 276 Chinese persons designated in 2024 reflect a different problem: third-country intermediaries in jurisdictions where compliance teams have lighter customer due diligence frameworks. Enhanced due diligence protocols built only around sanctioned-country nationals now miss a material category of risk.

The precedents are clear on what inadequate controls cost. BNP Paribas paid $8.9 billion in 2014 for processing transactions through shell companies linked to Sudan, Cuba, and Iran. Standard Chartered's 2019 settlement totaled $1.1 billion for Iranian sanctions violations routed through intermediaries. Both failures involved counterparties that looked clean on a surface screen but weren't on closer inspection.

Regulatory compliance automation addresses three gaps the volume growth creates: the frequency of list updates (OFAC updates the SDN list continuously, not on a fixed cycle), the breadth of counterparty relationships that need screening, and the documentation burden when a compliance decision needs to be defended. OFAC's risk-based approach guidance under FATF Recommendation 1 explicitly expects firms to calibrate their screening controls to the actual threat environment. An environment producing 3,135 new designations per year demands more than yesterday's threshold-based rules.

One practical implication that often gets overlooked: delistings matter too. 422 persons were removed from the SDN list in 2023. Firms that freeze accounts on designation and don't re-check for delistings create compliance exposure in the other direction. A functioning sanctions screening program processes both additions and removals in near-real-time.

Sources

• Center for a New American Security, "Sanctions by the Numbers: 2024 Year in Review," 2025
• Center for a New American Security, "Sanctions by the Numbers: 2022 Year in Review," 2023
• Center for a New American Security, "Sanctions by the Numbers: 2023 Year in Review," 2024
• Center for a New American Security, "Sanctions by the Numbers: 2021 Year in Review," 2022
• Center for a New American Security, "Sanctions by the Numbers: 2025 Year in Review," 2026
• Miller & Chevalier, "OFAC Year in Review 2024," 2025
• OFAC, "2024 Civil Penalties and Enforcement Information," U.S. Treasury
• OFAC, "Archive of Changes to the SDN List," U.S. Treasury