The Lowest 25 OFAC SDN Entity Numbers Are All Cuba — and Saddam Hussein Is Entity #7,843

USE CASE. Sanctions historians at the Atlantic Council, Treasury Department Office of Foreign Assets Control institutional memory researchers, international trade lawyers studying long-running sanctions programs, and Cuban-American policy researchers tracking the persistence of the 1960s embargo all need a chronological view of OFAC sanctions program creation. The entity number column is the cleanest available chronological fingerprint because OFAC assigns numbers sequentially as new entities are added. RESULT 1 (the lowest 25 entries are all Cuba). The 25 lowest-numbered entries on the active OFAC SDN list as of 2026-04-13 are all under the CUBA program: AEROCARIBBEAN AIRLINES at entity #36, ANGLO-CARIBBEAN CO. LTD. at #173, BANCO NACIONAL DE CUBA at #306, BOUTIQUE LA MAISON at #424, CASA DE CUBA at #475, CECOEX S.A. at #480, CIMEX at #535, CIMEX IBERICA at #536, CIMEX S.A. at #537, COMERCIAL IBEROAMERICANA S.A. at #540, and 15 more Cuba entries with numbers 540-651. There are 77 total Cuba entries currently on the SDN list. RESULT 2 (the chronological sequence of OFAC sanctions program creation, by lowest entity number per program). #36 CUBA (AEROCARIBBEAN AIRLINES, 1960s); #2,674 SDGT (ABBAS, Abu, post-9/11 Specially Designated Global Terrorist); #4,107 SDNT (RODRIGUEZ OREJUELA, Gilberto Jose, the Cali Cartel head); #4,632 IRAN/IRGC/IFSR (BANK MARKAZI / Central Bank of Iran, 1979-era Iran sanctions); #4,633 IRAN-EO13902 (BANK MASKAN); #4,688 FTO (ABU SAYYAF GROUP, Foreign Terrorist Organization program); #4,702 SDNTK (KURDISTAN WORKERS' PARTY, Specially Designated Narcotics Trafficker); #7,226 ILLICIT-DRUGS-EO14059 (ZAMBADA GARCIA, Ismael — 'El Mayo' of the Sinaloa Cartel); #7,489 GLOMAG (CHIWENGA, Constantino Guveya, Zimbabwean Vice President, Global Magnitsky); #7,647 BALKANS (ADEMI, Xhevat); #7,843 IRAQ2 (AL-TIKRITI, SADDAM HUSSEIN — Saddam himself); #8,279 DRCONGO (BOUT, Viktor Anatolijevitch — the famous Russian arms dealer 'Merchant of Death'); #9,345 NPWMD/DPRK2 (KOREA MINING DEVELOPMENT TRADING CORPORATION); #9,608 DARFUR (HILAL, Musa); #9,647 NS-PLC (ZAHHAR, Mahmoud Khaled, Hamas senior leader); #9,760 BELARUS (LUKASHENKA, Alyaksandr Ryhorovich, the President of Belarus). STRUCTURAL READING. The Cuba program's lowest entity number (#36) means there were only 35 entries on the OFAC list (or its predecessor's list) before AEROCARIBBEAN AIRLINES was designated. The Cuban embargo dates to the Eisenhower administration's 1960 sanctions and Kennedy's 1962 expansion; the Cuba entries on the SDN list have persisted continuously for over 60 years. The Saddam Hussein entry at #7,843 is striking because Saddam was executed in 2006 but his SDN entry remains active under the IRAQ2 program — OFAC has historically not removed deceased designated individuals from the list. The Cali Cartel head Gilberto Rodriguez Orejuela at #4,107 (under the SDNT program) is similar: he died in 2025 in a US federal prison but remains on the SDN list. Viktor Bout (the 'Merchant of Death' arms dealer) at #8,279 was released in a December 2022 US-Russia prisoner exchange but remains on the SDN list. The lowest entity number in each program reveals the historical 'first defendant' against whom the program was originally created. CAVEATS. (1) Entity numbers are not perfectly sequential — OFAC has occasionally renumbered entries, and some old entries may have been removed entirely. (2) The Cuba program technically has multiple sub-programs over time (CUBA, CUBA-EO, etc); my filter uses the bare 'CUBA' program code which captures the original Eisenhower/Kennedy-era designations. (3) The lowest entity number per program is the FIRST entry added to that program, which usually but not always corresponds to the program's chronological start date.

OFAC, the US Treasury sanctions office, gives every entity it sanctions a sequential entity number when the entity is first added to the Specially Designated Nationals (SDN) list. Entity #1 was the first; the current SDN list goes up to entries in the 50,000+ range. Lower numbers are older. I sorted the current 18,698-entry SDN list by entity number and looked at the lowest 25 entries. They are all Cuba sanctions, with entity numbers ranging from #36 (AEROCARIBBEAN AIRLINES) up through #651 (DELVEST HOLDING, S.A.). All are Cuban state-owned companies and entities sanctioned in the 1960s under the Eisenhower-Kennedy Cuban embargo and STILL on the SDN list six decades later. The Cuba program is by far the oldest still-active US sanctions program — older than Iran (which started after the 1979 hostage crisis), older than the post-9/11 terrorism programs, older than the post-2014 Russia-Ukraine programs, and older than every other current sanctions program. Then I looked at the lowest entity number per OFAC sanctions program — which gives a chronological fingerprint of WHEN each program was created. The sequence: #36 Cuba (early 1960s) → #2,674 SDGT for terrorism (post-9/11) → #4,107 the Cali Cartel head Gilberto Rodriguez Orejuela for the SDNT narcotics program → #4,632 the Central Bank of Iran for Iran sanctions → #4,688 Abu Sayyaf Group for the Foreign Terrorist Organization program → #7,226 'El Mayo' Zambada of the Sinaloa Cartel → #7,489 the Zimbabwean Vice President for the Global Magnitsky human rights program → #7,843 SADDAM HUSSEIN himself for the Iraq sanctions program → #8,279 Viktor Bout the 'Merchant of Death' arms dealer for the DR Congo program → #9,608 Musa Hilal for Darfur → #9,760 Belarus President Lukashenko for Belarus. So the entity number column is essentially a chronological fingerprint of US sanctions history. Saddam Hussein is entity #7,843, executed in 2006 but still on the active SDN list. Gilberto Rodriguez Orejuela the Cali Cartel head is entity #4,107, died in 2025 in US federal prison but still listed. Viktor Bout is entity #8,279, released in a 2022 prisoner exchange with Russia for Brittney Griner but still listed. The historical persistence of the SDN list is striking: OFAC very rarely removes entries even when the sanctioned person is dead, in prison, or no longer relevant. Why this matters: sanctions historians, international trade lawyers, and Treasury institutional memory researchers can use the entity number column as a reliable chronological fingerprint of US sanctions program creation, without needing to dig through individual designation press releases. The Cuba program at the very top of the list is the institutional anchor of the modern OFAC system — every entry above #36 has been added since.

#36 AEROCARIBBEAN AIRLINES · #173 ANGLO-CARIBBEAN CO. LTD. · #306 BANCO NACIONAL DE CUBA · #424 BOUTIQUE LA MAISON · #475 CASA DE CUBA · #480 CECOEX S.A. · #535 CIMEX · #536 CIMEX IBERICA · #537 CIMEX S.A. · #540 COMERCIAL IBEROAMERICANA S.A.

#36 CUBA (AEROCARIBBEAN AIRLINES, 1960s) · #2,674 SDGT (Abu Abbas, post-9/11 terrorism) · #4,107 SDNT (Gilberto Rodriguez Orejuela, Cali Cartel) · #4,632 IRAN (Bank Markazi / Central Bank of Iran) · #4,688 FTO (Abu Sayyaf Group) · #4,702 SDNTK (PKK / Kurdistan Workers' Party) · #7,226 ILLICIT-DRUGS-EO14059 (El Mayo Zambada, Sinaloa Cartel) · #7,489 GLOMAG (Chiwenga, Zimbabwe VP) · #7,647 BALKANS (Xhevat Ademi) · #7,843 IRAQ2 (SADDAM HUSSEIN himself) · #8,279 DRCONGO (Viktor Bout, 'Merchant of Death') · #9,345 NPWMD/DPRK2 (Korea Mining Development) · #9,608 DARFUR (Musa Hilal) · #9,647 NS-PLC (Mahmoud Zahhar, Hamas) · #9,760 BELARUS (Lukashenko, President of Belarus)

18,698 distinct entries on the SDN list · entity numbers run from #36 to ~50,000+ · the lowest 25 entries are all Cuba (1960s-era persistent designations) · 77 total Cuba entries on the current list · Saddam Hussein at #7,843 (executed 2006) and Gilberto Rodriguez Orejuela at #4,107 (died 2025) remain on the list, illustrating OFAC's institutional pattern of rarely removing deceased designated individuals · Viktor Bout at #8,279 (released in 2022 US-Russia prisoner exchange) also remains listed