Specially Designated Nationals

The Office of Foreign Assets Control (OFAC), Department of the Treasury,
implements and enforces financial and trade sanctions. FAC has the
authority to include within the definition of the sanctioned government
those individuals and entities that FAC has determined are owned by,
controlled by, or acting directly or indirectly on behalf of the target
government. Parties so identified are known as Specially Designated
Nationals or SDNs. In practice, an SDN is a target government body,
representative, intermediary, or front (whether overt or covert) that
usually is located in a third country and functions as an extension of the
sanctioned government. An SDN may also be a third-party company that
otherwise becomes owned or controlled by the target government or that
operates on its behalf. No criminal linkage is necessary. Ownership by,
control by, acting on behalf of, or profiting from trade with the target
government or country would suffice to qualify a person for designation.