OFAC vs OpenSanctions: A Practical Guide to Sanctions List Coverage
Should you screen against OFAC only or add UN, EU, and UK lists? Compare coverage, data formats, and implementation approaches for VASP compliance.
If you're building sanctions screening for a VASP, the first question is simple: which lists do you screen against?
Most crypto compliance teams start with OFAC — the US Treasury's Specially Designated Nationals (SDN) list. It's the most consequential sanctions list in the world. But OFAC alone leaves significant gaps.
OFAC SDN: The Foundation
The Office of Foreign Assets Control maintains the SDN list — individuals, entities, vessels, and aircraft subject to US sanctions. Free CSV/XML downloads, updated irregularly (~daily), no API.
Strengths: Authoritative source, most consequential globally, well-structured data. Limitations: US-centric only, missing EU/UK/UN sanctions, basic CSV format.
OpenSanctions: The Aggregator
OpenSanctions aggregates sanctions data from 332 global sources into a unified database. Covers OFAC + UN Security Council + EU Financial Sanctions + UK FCDO + 85 national regimes + PEPs from 28+ countries. Updated daily, free bulk downloads.
Strengths: Comprehensive global coverage, cross-list deduplication, includes PEP data. Limitations: Not an authoritative source (aggregator), commercial license needed for business use, potential ingestion lag.
Side-by-Side Comparison
| Aspect | OFAC SDN | OpenSanctions |
|---|---|---|
| Sources | 1 (US Treasury) | 332 global sources |
| PEP data | No | Yes (28+ countries) |
| Cost | Free | Free (non-commercial) / Paid (commercial) |
| Update frequency | Irregular (~daily) | Daily |
| Entity deduplication | N/A | Cross-list deduplication |
Why You Need Both
If your VASP operates across jurisdictions, OFAC alone doesn't satisfy compliance obligations. EU MiCA/TFR requires screening against EU sanctions. UK FCA expects UK OFSI screening. APAC regulators reference FATF guidance implying UN list screening.
A person sanctioned by the EU may not appear on OFAC — and vice versa.
Our Approach
At ComplyVASP, we use self-hosted OFAC SDN data combined with OpenSanctions bulk downloads for UN, EU, and UK lists. Every entity search queries all four sources simultaneously, with results showing which list each match comes from.
Try our multi-source sanctions checker — screen entities against OFAC + UN + EU + UK in a single query. Launch Sanctions Checker →
Sources
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Run Free Screening →This article is provided for informational purposes only and does not constitute legal advice. Always verify with official sources and professional counsel before making compliance decisions.