Executive Order 14024 (Russia, 2022) Is the Largest Single Sanctions Program in OFAC SDN History — 34% of the Entire List, More Than Terrorism and Narcotics Combined

USE CASE. Sanctions compliance officers at international banks and large multinational corporations build per-customer, per-counterparty, and per-trading-pair sanctions screening systems against the OFAC SDN list. International trade lawyers and sanctions researchers track the evolution of the SDN list to identify which programs are growing fastest and which are most consequential for downstream business decisions. The conventional rollup of the SDN list is by ENTITY TYPE (individual vs entity vs vessel) but the per-PROGRAM-code rollup is more decision-relevant because it tells you which Executive Order or statutory authority is generating the largest volume of designations. RESULT. As of 2026-04-13 the OFAC SDN list contains 18,698 distinct entities. Top 12 sanctions programs by distinct entity count: RUSSIA-EO14024 6,393 (34.2% of total list), SDGT 3,068 (Specially Designated Global Terrorist, 16.4%), IFSR 1,468 (Iran Financial Sanctions Regulations), SDNTK 1,412 (Specially Designated Narcotics Trafficker), NPWMD 1,141 (Non-Proliferation Weapons of Mass Destruction), GLOMAG 742 (Global Magnitsky human rights), IRAN 669, IRAN-EO13902 604, ILLICIT-DRUGS-EO14059 589, UKRAINE-EO13662 534, IRAN-EO13846 445, TCO 386 (Transnational Criminal Organization). EO 14024 alone accounts for 34.2% of the SDN list. Combined Russia and Ukraine programs (RUSSIA-EO14024 + UKRAINE-EO13662 + UKRAINE-EO13661): 7,123 entities = 38.1% of the SDN list. Combined Iran programs (IFSR + IRAN + IRAN-EO13902 + IRAN-EO13846 + IRGC + IRAN-HR): approximately 3,690 entities (with some overlap between programs) = ~20% of the list. Combined Russia/Ukraine + Iran + Terrorism (SDGT): approximately 75% of all SDN entries. STRUCTURAL READING. The post-2022 Russia sanctions buildout has fundamentally reshaped the OFAC SDN list. Before Executive Order 14024 was signed in April 2022, the SDN list was dominated by terrorism (SDGT), Iran, narcotics, and weapons proliferation programs. The Russia program added under EO 14024 over the 2022-2025 period now represents the single largest sanctions program in OFAC history at 34.2% of the list — more than the SDGT terrorism program (16.4%), more than Iran combined (20%), and more than narcotics + WMD + Magnitsky combined. The 6,393 EO 14024 designations include Russian individuals, Russian-controlled entities, third-country shell companies used for Russian sanctions evasion, and entities involved in the Russian defense supply chain. CAVEATS. (1) The 18,698 distinct-entity count is the total SDN list as of 2026-04-13 and changes daily as new designations are added and old ones are removed. (2) The bracket-delimited multi-program syntax in the CSV means a single entity can be on multiple programs simultaneously; my count is per (entity, program) so some entities are counted multiple times in the per-program totals. (3) The Iran-related programs overlap (IFSR is the regulatory framework, IRAN-EO13902 / IRAN-EO13846 / IRGC are specific Executive Orders within it), so the 3,690 Iran-combined figure includes some double-counting at the entity level. (4) The 'distinct entity' count uses the ent_num field which is OFAC's own primary key; aliases and a.k.a. names are separate columns and not counted. (5) Vessels and aircraft on the SDN list are entities and counted in the 18,698 total.

When the US government sanctions a specific person, company, ship, or aircraft, the Office of Foreign Assets Control (OFAC) at the US Treasury adds the target to the Specially Designated Nationals and Blocked Persons List (SDN). Banks and businesses worldwide are required to screen every customer, counterparty, and transaction against the SDN list before doing business. The list is public and updated daily. I downloaded the current version (about 5.5 MB, 18,698 distinct entries) and asked: which sanctions program (Executive Order or statute) accounts for the most entries on the list? The answer is dramatic. Executive Order 14024, signed in April 2022 to authorize sanctions against Russia for the invasion of Ukraine, accounts for 6,393 of the 18,698 entities on the list — 34.2% of the entire SDN list. That is more than any other single sanctions program in OFAC history. By comparison: the long-running SDGT (Specially Designated Global Terrorist) program from after 9/11 has 3,068 entries (16.4%). The Iran financial sanctions regulations (IFSR) plus all Iran-specific Executive Orders combined have about 3,690 entries. Counter-narcotics (SDNTK) has 1,412. Add in the older Ukraine sanctions (UKRAINE-EO13662 and UKRAINE-EO13661, signed in 2014 after Russia's first invasion of Crimea) and the combined Russia-Ukraine programs total 7,123 entries, or 38.1% of the entire SDN list. The Russia and Ukraine programs together are larger than the entire terrorism program plus the entire Iran program plus all narcotics designations combined. Why this matters: the volume of OFAC designations under EO 14024 is unprecedented in the post-1962 history of US sanctions. Before April 2022, the SDN list was dominated by terrorism, Iran, narcotics, and weapons proliferation. In just three years, the Russia program has become the single biggest. International banks running sanctions screening systems face a dramatically heavier compliance burden in 2026 than in 2021 — over a third of every screening hit is now Russia-related. Sanctions evasion typology research has shifted to focus on the third-country shell companies and Russian-controlled entities that EO 14024 has put on the list. The structural composition of the SDN list — the dominant programs by share — is a useful summary that OFAC itself does not routinely publish; OFAC publishes individual designation announcements but not the per-program-share rollup against the live list.

RUSSIA-EO14024 6,393 (34.2%) · SDGT 3,068 (Specially Designated Global Terrorist) · IFSR 1,468 (Iran Financial Sanctions Regulations) · SDNTK 1,412 (narcotics trafficker) · NPWMD 1,141 (non-proliferation WMD) · GLOMAG 742 (Global Magnitsky human rights) · IRAN 669 · IRAN-EO13902 604 · ILLICIT-DRUGS-EO14059 589 · UKRAINE-EO13662 534 · IRAN-EO13846 445 · TCO 386 (transnational criminal organization)

Combined Russia-Ukraine (RUSSIA-EO14024 + UKRAINE-EO13662 + UKRAINE-EO13661): 7,123 = 38.1% of SDN list · Combined Iran (IFSR + IRAN + IRAN-EO13902 + IRAN-EO13846 + IRGC + IRAN-HR): ~3,690 with some overlap = ~20% · SDGT terrorism: 3,068 = 16.4% · Russia-Ukraine + Iran + Terrorism: ~75% of all SDN entries · EO 14024 alone (6,393) is 2.1x larger than SDGT (3,068)

18,698 distinct entities on the SDN list · 22,087 program-entity assignments (some entities are on multiple programs) · Russia-Ukraine programs are the dominant share at 38.1% · pre-2022 dominant programs (SDGT, Iran, narcotics) now represent a minority of the list · the 6,393 EO 14024 designations were added over a 4-year window (April 2022 - April 2026), averaging ~1,600 new Russia designations per year