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| Figure/Metric | Value | Source | Significance |
|---|---|---|---|
| April 2026 Additions | 172 | JD Supra / OFAC | High-fidelity monthly count for individuals and entities. |
| May 2026 Additions | 164 | JD Supra / OFAC | High-fidelity monthly count; confirms high run-rate. |
| June 2026 (Partial) | ~110-130 | OFAC Recent Actions | Estimated based on itemized tranches (Prince Group, Sudan, Cuba). |
| Total SDN List Size | >17,000 | US Treasury (May 2026) | Indicates the scale of the list and the complexity of compliance. |
| Annual Additions (2024) | >3,000 | Reuters / Treasury | Provides a historical baseline for high-activity years. |
The pace of OFAC designations has increased dramatically over the last decade. In 2017, the annual number of new names added to sanctions lists was approximately 880. By 2024, this figure had risen to over 3,000, driven by the intensive use of sanctions following the invasion of Ukraine and increased targeting of Iranian and North Korean procurement networks. Historically, SDN list growth is non-linear, often characterized by ‘tranches’ where 20-50 entities are added in a single day, often following a major geopolitical event or a shift in executive policy. In early 2026, the ‘Economic Fury’ campaign marked a specific strategic pivot toward aggressive, multi-theater enforcement, leading to the high volumes observed in the April-May 2026 period.
My analysis is based on a aggregation of specific monthly and daily reporting from OFAC Recent Actions and legal summaries for the first half of 2026.
The baseline for this forecast is the high-fidelity data available for Q2 2026. Authoritative legal trackers (JD Supra) reported 172 individual and entity additions in April 2026 and 164 in May 2026, excluding vessels and administrative updates. This provides a clear ‘high-activity’ benchmark for the current administration’s ‘Economic Fury’ campaign. For June 2026, I itemized several large tranches, including 34 new entries for the Prince Group (after excluding one prior designation), 11 for Mexican fuel theft networks, 8 for Sudan-related actors, and 6 for the Cuban regime. While some June notices were not fully quantified in the reports, the aggregate June total is estimated at 110–130.
The period from January to March 2026 is less precisely documented but contains high-profile designations including the ICC prosecutor, the Colombian President’s inner circle, and various Georgian and Brazilian officials. Based on the frequency of update dates (9 in January, 2 in February), I estimate Q1 additions at approximately 100–140. Combining these periods, the cumulative total through June 30, 2026, is approximately 545–605.
The final month of the window (July 1 to August 1) represents the primary area of uncertainty. Given the recent average monthly rate of ~145 additions (April–June), a similar performance in July would result in a total between 690 and 750. I have weighted my prediction toward 685, accounting for the possibility that June’s slightly lower pace (relative to April/May) might continue into July.
To account for alternative scenarios, I considered a high-activity outcome (~850+), which would occur if July sees a ‘mega-tranche’ related to Iran’s energy sector or Russian military procurement, similar to the 43-entry action on May 1. Conversely, a low-activity outcome (~545) would require July to be an exceptionally quiet month for designations, which is unlikely given the current geopolitical climate and active ‘Economic Fury’ initiative. My most likely value of 685 represents a balanced continuation of the recent three-month average.
Question: what is the total number of OFAC SDN individual/entity additions from Jan. 1–Aug. 1, 2026? Forecasters agree the window is mostly observed and the key uncertainty is the remaining July/ Aug. 1 increment and the risk of one lumpy “megabatch.” Agents parsed an exact January subtotal of 84 and a partial Jan–Jun parse of 125 qualifying additions (so a final count below ~145 is very unlikely), but no complete YTD machine-readable count was produced yet—so the recommended workflow is to parse OFAC Recent Actions (count only “individual/entity added” rows), dedupe by ENT_NUM in SDN XML/CSV, and then forecast the remaining July increment. Teams converge on a mid‑hundreds outcome: medians in the mid‑500s to low‑600s (one model centers ~600–700), with routine Iranian, cartel/TCO, Sudan/DRC and other program notices supplying most run‑rate additions and Russia as the principal fat‑tail driver. All provide a meaningful but small upper tail for a late large package (forecasters reserve a modest ~5%+ chance of exceeding ~1005 if a Russia/Iran megabatch occurs).
Forecast: Probability distribution:
We are forecasting gross additions of SDN “Individual” and “Entity” entries (unique ENT_NUMs), excluding vessels/aircraft, from Jan 1 through Aug 1, 2026. With today at Jul 1, most of the window has already occurred; the remaining uncertainty is dominated by July (and any Aug 1 actions) plus uncertainty about the already-realized Jan–Jun total.
Across analysts, the most concrete and internally consistent information is the month-by-month 2026 figures cited by Forecaster 4 (Jan 84, Feb 82, Mar 34, Apr 172, May 164 = 536 through May), which also matches Forecaster 1’s specific Jan/Feb counts. That implies the final answer is very likely well above 600 once June and July are included. Forecaster 3’s median (~520) is therefore likely inconsistent with these already-realized totals (unless the monthly figures are substantially mismatched to the resolution definition), so I downweight it.
Forecaster 2 appears to be using an “early June 614” figure in a way that likely overstates Individuals+Entities (it may include vessels/aircraft or other counting differences) and their provided percentile table is not monotone (p90/p95/p99 below earlier percentiles), so I treat it mainly as an argument for a fatter upper tail rather than as a good central estimate.
Forecaster 4’s central estimate (~710) seems plausible but their interval is too tight given (a) uncertainty in mapping secondary summaries to unique ENT_NUM additions, (b) the remaining month can still contain a large batch action, and (c) OFAC additions are lumpy. I therefore keep a similar center but widen the distribution, with a modest (few percent) chance of exceeding the platform’s 1005 open upper bound (requiring an unusually large July).
Net: median in the low-to-mid 700s, with a wide right tail and a non-trivial but not dominant chance of a very large July package.
An amateur forecast would likely (1) anchor on a simple annualized average from a different year (e.g., the Russia-driven 2024 pace) or (2) ignore that six months of the measurement window have already elapsed and that vessels/aircraft are excluded. My forecast conditions on the already-cited 2026 monthly additions through May (a strong constraint on the floor), then explicitly models July’s event-driven lumpiness with a wider upper tail while discounting an internally inconsistent high forecast. Confidence in improvement is moderate: the main remaining risk is misalignment between secondary monthly summaries and the resolution’s unique-ENT_NUM counting rules.
Forecast rationale (numeric):
— Iteration 1 — Overall, the forecasts center on a moderate level of new OFAC SDN additions over the Jan. 1–Aug. 1, 2026 window, with point estimates clustering roughly in the low-400s to mid-500s. The shared view is that 2026 so far looks active but not exceptionally heavy in the way a major Russia-style sanctions surge might be.
The collective reasoning suggests a moderately active 2026 OFAC designation pace, tempered by indications of a somewhat more selective or moderated sanctions environment. The most likely outcome is a total in the few-hundred range, with the distribution kept broad to account for OFAC’s episodic, package-based behavior.
— Iteration 2 — The forecasts converge on a moderate-to-high number of SDN additions, centered around roughly 450–530, with a broad plausible range that stays mostly below the upper bound of about 1,005.
Overall, the collective reasoning points to steady OFAC sanctioning activity in 2026, moderated by a more selective policy posture, with the final count likely in the low-to-mid hundreds rather than an extreme surge.
— Iteration 3 — Across the forecasts, the dominant view is that OFAC will add several hundred new individuals and entities to the SDN List in the Jan. 1–Aug. 1, 2026 window, with a central tendency in the mid-hundreds rather than near the low end of the range.
The combined reasoning points to a mid-hundreds outcome with wide uncertainty, driven by OFAC’s historically bursty sanctions behavior, ongoing geopolitical targeting, and the possibility that one large action could substantially change the final total.
Summary of Rationale Arguments
To forecast the number of new individuals and entities added to OFAC’s Specially Designated Nationals (SDN) List between January 1 and August 1, 2026, the rationales rely on a bottom-up approach: aggregating reported designations from the first half of the year, filtering out ineligible categories, and projecting July’s volume based on structural policy shifts and scheduled geopolitical catalysts.
Baseline Data and Structural Shifts (January–June 2026) Forecasters widely agree on a well-documented baseline of gross designations made during the first five months of 2026. However, the resolution criteria strictly exclude vessels and aircraft. Because OFAC heavily targeted Russian and Iranian “shadow fleets” during this period, a notable portion of these gross additions must be subtracted to isolate human individuals and corporate entities.
Furthermore, the volume of additions is structurally constrained by the Treasury’s newly announced “Sanctions Modernization Initiative.” This strategic pivot moves away from the massive, bulk listings seen during the 2022–2024 peak of the Russia-Ukraine war, favoring smaller, highly targeted enforcement actions against complex evasion networks. June’s activity reflected this steady, targeted pace, featuring specific tranches directed at cyber-fraud (the Prince Group), Mexican cartels (CJNG), Sudan, Cuban leadership, and ISIS facilitators.
July Catalysts (Upward Pressures) Forecasters anticipate that July will feature several major events that traditionally spur coordinated sanctions packages, preventing a complete summer lull:
July Suppressors (Downward Pressures) Conversely, the biggest constraint on July’s designation volume is a temporary diplomatic thaw with Iran. Following a recent diplomatic understanding (the “Islamabad MOU”), OFAC issued a 60-day sanctions waiver (General License X) in late June. Forecasters overwhelmingly agree that this waiver will effectively pause enforcement against Iranian energy and shadow-banking networks, severely curtailing what is ordinarily one of OFAC’s highest-volume sanctions programs through the end of the forecasting window.
Question: How many new individuals and entities will be added to OFAC’s SDN List between January 1, 2026 and August 1, 2026? Final Prediction: Probability distribution:
Total Cost: extra_metadata_in_explanation is disabled Time Spent: extra_metadata_in_explanation is disabled LLMs: extra_metadata_in_explanation is disabled Bot Name: extra_metadata_in_explanation is disabled
Forecaster 1: Probability distribution:
Forecaster 2: Probability distribution:
The research compiles historical base rates, recent monthly data (Jan–Jun 2026), and contextual drivers to forecast gross additions to OFAC’s SDN list for Jan 1–Aug 1, 2026 (7 months). Key historical figures: 743 additions in 2021; 2,502 in 2023; 3,135 in 2024 (about 70% Russia-related); and 1,764 in 2025 (the 2025 Trump administration pace ≈110 additions/month, with only 74 Russian persons added that year). Monthly averages cited include ~261/month for 2024 and ~110/month for the 2025 Trump-period baseline. Confirmed 2026 data include April 2026 = 172 additions (vessels excluded per criteria), May 2026 = 141 verified sanction events, and numerous named events Jan–Jun (IRGC commanders, Iran-linked individuals/entities, cartel and transnational crime designations, etc.). The research also notes significant delistings in 2026 (e.g., May 28 removals of ~76–80 names), but explicitly treats removals as not subtracting from gross-addition counts.
Using these reference classes and observed 2026 pace, the research provides three scenario estimates for the seven-month Jan 1–Aug 1, 2026 window: a conservative projection based on the 2025 Trump pace (110/month) → ~770 additions; a mid-range projection based on April 2026’s higher pace → ~900–1,000 additions; and a higher-intensity scenario (2024-like) → ~1,050–1,260 additions (deemed less likely). The report’s “most likely range” is 750–1,000 individuals and entities. It lists upward pressure drivers (Iran sanctions escalation, continued cartel-related designations, China-related targeting, and occasional large batch designations) and downward pressures (OFAC streamlining/delistings, reduced Russia sanctions, Venezuela licenseing, and potential Iran waivers). The research notes no active prediction-market forecasts were found for this specific question and flags data-quality points (SDN list ~17,000 names as of May 2026; OFAC updates multiple times per business day; Unique ENT_NUM identifiers are the definitive measure).
Sources/websites used (as stated in the research):
Based on my research, I’ll provide you with a comprehensive analysis of historical base rates, recent trends, and relevant context for forecasting OFAC SDN List additions between January 1, 2026 and August 1, 2026.
The second Trump administration dramatically reduced Russia-related sanctions (only 74 Russian persons added in 2025, down from 70% of all 2024 additions) while shifting focus to: [30]
However, per your criteria, removals do NOT subtract from the count—only gross additions matter.
For the January 1 - August 1, 2026 period (7 months):
Conservative Estimate (based on 2025 Trump pace):
Mid-Range Estimate (based on April 2026 actual):
Higher Estimate (if 2024-like intensity returns):
Most Likely Range: 750-1,000 individuals and entities for the January 1 - August 1, 2026 period
This estimate is based on:
I did not find any active prediction markets (Polymarket, Kalshi, Manifold, etc.) specifically forecasting this OFAC SDN question. This appears to be a novel forecasting question.
I agree with the critic’s latest pushback: my previous median of 800 probably over-corrected downward. Conditioning on the question resolving normally, the forecast should now be driven primarily by the fixed Jan. 1–June 30 accrued count, plus July/Aug. 1 additions.
The most important update is that a stricter pass through June 2026 OFAC notices supports the critic’s higher June count of about 129 countable Individual/Entity additions. The official notices show examples like June 30: 2 individuals + 9 entities = 11, June 23: 9 individuals + 31 entities = 40, June 25: 2 individuals + 4 entities = 6, June 22: 3 individuals + 6 entities = 9, and June 5: 4 individuals + 12 entities, with vessels separately listed and excluded. The June 25 notice also explicitly labels later material as administrative corrections with no new listings, reinforcing the need not to count every name shown on a notice. (ofac.treasury.gov)
I still would not take the Fluet 614 designations / 255 removals / 869 total actions figure as a clean count for this question, because it appears to discuss SDN activity broadly and explicitly references individuals, entities, and vessels. But it is useful as a noisy upper-bound/activity indicator. Combining that with the now-more-solid June count makes my earlier Jan–June center of ~685–710 look too low; I now think the fixed Jan–June countable total is more likely around 710–730, with meaningful uncertainty from Jan–May vessel-heavy or mixed-update actions. (fluet.law)
I still defend the broader structure of the forecast: the 2024 Russia-heavy sanctions pace is a poor anchor, vessel-heavy Iran actions can look large while adding fewer countable entries, and >1,000 still requires a very large July/Aug. 1 increment unless the accrued count is already surprisingly high. If the accrued count is around 720, then exceeding 1,000 requires roughly 280+ further countable additions after June 30, so I keep that tail real but not dominant.
For July plus August 1, I model a median around 90–100 countable additions: a quiet post-July-4 / post-late-June-pull-forward month could be 40–70, while a major TCO/cartel, Cuba, cyber/scam-network, Iran-finance, or sanctions-evasion package could add 150–250+. Netting this against a revised accrued baseline gives me a median around 815, with P(>1000) roughly 8–9%.
Updated prediction:
Percentile 0.1: 535
Percentile 1: 610
Percentile 5: 685
Percentile 10: 715
Percentile 20: 750
Percentile 30: 778
Percentile 40: 798
Percentile 50: 815
Percentile 60: 842
Percentile 70: 876
Percentile 80: 922
Percentile 90: 982
Percentile 95: 1075
Percentile 99: 1350
Percentile 99.9: 1750
Conditioned on the question not being annulled, I agree with the critic’s main direction: my prior median was still a bit too high. The remaining uncertainty is now mostly “how many countable July additions?”, not a broad seven-month base-rate problem.
The strongest anchor remains the observed subtotal. Hughes Hubbard reports 84 countable individuals/entities in January, 82 in February, 34 in March, 172 in April, and 164 in May, with vessels separately identified where relevant. That gives 536 through May. (hugheshubbard.com) My own recheck of official June notices gives about 128, not materially different from the prior ~129 estimate: June 23 was the largest late-June action at 9 individuals + 31 entities, while several other June actions were single-digit or low-double-digit countable additions; June 30, for example, added 2 individuals + 9 entities and separately listed deletions that do not count. (ofac.treasury.gov) So my working subtotal is now ~664 through June 30.
The critic is right that April/May should be treated more as a spring burst than the default July pace. The Jan–Jun sequence is roughly 84, 82, 34, 172, 164, 128, with a mean near 111/month and a median near 106/month. Given the holiday-shortened first week of July, the Saturday August 1 endpoint, and the recurring issue that many OFAC notices involve removals, updates, licenses, vessels, or administrative changes, I now prefer a July median around 115–120 countable additions, not 125–140.
I still defend keeping a meaningful right tail. Cuba/TCO/scam-center actions, cartel networks, Iran shadow-banking—not just vessel-heavy shadow-fleet actions—and counterterrorism channels can still generate a large non-vessel tranche. But getting above 1,000 total requires roughly 335+ additional July/August-1 countable additions from a ~664 base, which is a very high one-month bar. I now put P(>1000) at roughly 4%.
So I’m making a modest downward adjustment from my prior median of 790 to about 781, with the upper-middle tail also slightly lower.
Updated prediction:
Percentile 0.1: 642
Percentile 1: 670
Percentile 5: 694
Percentile 10: 711
Percentile 20: 734
Percentile 30: 752
Percentile 40: 767
Percentile 50: 781
Percentile 60: 800
Percentile 70: 823
Percentile 80: 848
Percentile 90: 898
Percentile 95: 955
Percentile 99: 1120
Percentile 99.9: 1400
Modal: 683-790 (28.7%) • frontier aggregate • 7m31s
Resolution sources/checks:
Edge cases:
frontier_1 - Modal: 683-790 (45.0%)
frontier_2 - Modal: 683-790 (20.0%)
frontier_3 (revised) - Modal: 683-790 (35.0%)
frontier_4 - Modal: 790-898 (28.0%)
frontier_5 - Modal: 575-683 (24.0%)
Material notes
Guidance
Revision
| Bin | Probability |
|---|---|
| Below 145 | 0.5% |
| 145-253 | 1.0% |
| 253-360 | 2.5% |
| 360-468 | 5.9% |
| 468-575 | 11.2% |
| 575-683 | 20.8% |
| 683-790 | 28.7% |
| 790-898 | 17.6% |
| 898-1005 | 8.1% |
| Above 1005 | 3.6% |
wooley_rhino • run 326baea4 • $3.28 • 7m31s
Extracted Percentile Values: {0.1: 490, 1.0: 575, 5.0: 630, 10.0: 670, 15.0: 700, 20.0: 720, 25.0: 740, 30.0: 755, 35.0: 770, 40.0: 785, 45.0: 800, 46.0: 803, 47.0: 806, 48.0: 809, 49.0: 812, 50.0: 820, 51.0: 828, 52.0: 832, 53.0: 836, 54.0: 840, 55.0: 845, 60.0: 865, 65.0: 885, 70.0: 910, 75.0: 935, 80.0: 965, 85.0: 1000, 90.0: 1050, 95.0: 1130, 99.0: 1320, 99.9: 1600}
Model’s Answer:
The most actionable data point comes from the social media research, which specifically states “~614 designations and 255 removals in 2026 through ~47 action days (as of late May/early June).” This is the most direct, recent numerical anchor I have.
Additionally:
These three sources converge on a monthly rate of approximately 120–130 new individuals and entities per month in the current policy environment.
The 614 figure covers through approximately May 31 (5 months). Remaining window:
Rough projected total: 614 + ~60 (June) + ~125 (July) ≈ 800
But given the confirmed June activity which appears robust (multiple large packages), June additions may be closer to 60-80. Center estimate: ~800-850.
Assumption A — The monthly designation rate (~123/month) continues through August 1. If OFAC significantly slowed designations due to policy change or staffing issues, the total could fall toward 650-700. Probability this assumption fails significantly: ~10%.
Assumption B — No major geopolitical event (e.g., Russia re-escalation, Iran military confrontation) triggers a mass designation wave. If such an event triggered 400+ rapid designations (as seen in 2022 Russia actions), the total could reach 1,200+. Probability: ~8%.
Assumption C — The “614 through late May/early June” figure is accurate and complete, and not understated. If it undercounts, my baseline shifts up. Probability of material undercount: ~10%.
Low scenario (~5th percentile, ~580): A sharp policy pivot causes OFAC to halt major programs or redirect focus, severely curtailing additions in June-July. Unlikely given the active June evidence.
High scenario (~95th percentile, ~1,150): A major geopolitical event triggers Russia-scale mass designations or Iran reimposition at scale, producing 400+ additional entries in July alone on top of the current pace. Plausible but not the base case.
The data strongly suggests a central estimate of 780-860, with right skew due to the potential for geopolitical surges. Using a roughly log-normal-shaped distribution centered around 820-840:
Percentile .1: 490 Percentile 1: 575 Percentile 5: 630 Percentile 10: 670 Percentile 15: 700 Percentile 20: 720 Percentile 25: 740 Percentile 30: 755 Percentile 35: 770 Percentile 40: 785 Percentile 45: 800 Percentile 46: 803 Percentile 47: 806 Percentile 48: 809 Percentile 49: 812 Percentile 50: 820 Percentile 51: 828 Percentile 52: 832 Percentile 53: 836 Percentile 54: 840 Percentile 55: 845 Percentile 60: 865 Percentile 65: 885 Percentile 70: 910 Percentile 75: 935 Percentile 80: 965 Percentile 85: 1000 Percentile 90: 1050 Percentile 95: 1130 Percentile 99: 1320 Percentile 99.9: 1600
Sanctions architecture and OFAC publication cadence impose steady limits on daily processing and tranche sizes.
Statutory program scope and interagency priorities set multi-month ceilings and floors that anchor additions.
The first-half accumulation through June supplies a substantive base that constrains downside for the July window.
Recent months show persistent additions across counter‑narcotics, TCO, Cuba, and Sudan channels, sustaining upward pressure.
A single coordinated tranche tied to a major theater or designation campaign can add hundreds and shift the outcome decisively.
Sustained licensing, diplomatic de‑escalation, or an administrative pause can compress additions into a quieter summer window.
Principal uncertainties are the timing and grouping of July publications and any abrupt geopolitical escalation.
Key sensitivities are how entries are classified and dated, whether large packages are batched, and whether license actions reduce bulk additions.
Forecast: median = 910.4745 (new OFAC SDN Individuals + Entities added between Jan 1 and Aug 1, 2026).
As of Wednesday, July 1, 2026, OFAC’s Sanctions List Updates archive currently shows the latest sanctions-list update on June 30, 2026, and the Jan-Jun 2026 archive pages show the cadence of sanctions-list-update notices across the period. (ofac.treasury.gov)
The recent-action notice pages are the most useful operational source because each notice separates additions by individuals, entities, and vessels, and also has a separate unrelated administrative list changes section; that matches the resolution rule to count only new individuals and entities and exclude administrative-only changes. (ofac.treasury.gov)
I exactly counted January-February 2026 additions from the individual notice pages: January 13 = 4, January 15 = 24, January 16 = 22, January 21 = 8, January 22 = 10, January 23 = 8, January 30 = 9, February 6 = 17, February 10 = 6, February 19 = 26, February 24 = 7, February 25 = 20, and February 26 = 5, for a January-February subtotal of 166. (ofac.treasury.gov)
For March 2 through June 30, 2026, I count 36 additional sanctions-list-update notices whose titles indicate at least one new designation. Many of those titles are narrow or singular, such as Democratic Republic of the Congo-related Designation on April 30, 2026, International Criminal Court-related Designation on May 27, 2026, and Cuba Designation on June 11, 2026, while others are broader multi-program packages. My inference is that these March-June notices contributed roughly another 230 to 270 individual/entity additions, which puts the observed total through June 30 in the neighborhood of about 395 to 435. (ofac.treasury.gov)
From there, the forecasting question is mainly about July 1, 2026 through August 1, 2026. Recent pages show a dense May-June cadence, but many notices were small; my base case is that July contributes roughly 45 to 70 more individual/entity additions, with upside if OFAC publishes another large Iran-, Russia-, counterterrorism-, or counter-narcotics-related package. Combining that with the estimated June 30 running total gives a central estimate around 470, with most probability between about 390 and 590 and only a thin tail above 700. Reaching above 1000 by August 1 would require an unusually extreme July surge relative to the already-observed first-half cadence, so I assign that outcome only a very small probability. This last step is an inference rather than a direct count. (ofac.treasury.gov)
I used OFAC’s official Recent Actions pages for the Sanctions List Updates category as the primary evidence, and cross-checked that OFAC also maintains a 2026 SDN archive/changes PDF that records additions, changes, and removals since January 1, 2026. The Jan-Jun 2026 action cadence is visible across pages 1-7 of the Sanctions List Updates listing. (ofac.treasury.gov)
The directly inspected June action pages alone already add up to 108 new individuals/entities: June 30 = 11, June 26 = 8, June 25 = 3, June 23 = 40, June 22 = 3, June 18 = 8, June 11 = 1, June 5 = 16, June 4 = 10, and June 2 = 8. June 23 was especially large, with 9 individuals and 31 entities; June 30 had 2 individuals and 9 entities; June 5 had 4 individuals and 12 entities. (ofac.treasury.gov)
Late May and late April also look busy rather than quiet. Examples from inspected pages: May 18 added 9 individuals and 1 entity; May 27’s ICC action added 1 individual; April 30 added 1 individual; and April 23 already shows at least 14 individuals and 9 entities in the visible portion alone, indicating another large multi-program package. Several other inspected pages clearly show nontrivial additions as well, including May 11, May 28, May 29, April 24, and April 28. (ofac.treasury.gov)
Because I could not fully enumerate every Jan-Apr page entry line by line from the fetched excerpts, I treat the Jan-Jun realized total as an inference rather than a precise count. My lower-bound count from the directly visible entries is already well above 200, and the listing pages show many additional designation dates in January, February, March, and April. Given the observed sizes of the visible packages, I infer the realized total through June 30 is roughly 395-415, centered near 405. (ofac.treasury.gov)
For the remaining period from July 1 through August 1, 2026, I model roughly one more month of sanctions activity. June’s inspected actions alone produced 108 additions, and May/April also showed repeated multi-program designation days, so a reasonable forward add-on is about 35-65 more names, with upside risk if another large Iran-, counterterrorism-, cyber-, TCO-, or counternarcotics-related package lands. (ofac.treasury.gov)
That gives me a final point forecast near 450 total additions for the full January 1 to August 1 window. I place most probability mass between about 380 and 540. Below 150 is essentially negligible given the already-observed 2026 flow, while above 1000 would require a pace far beyond what the Jan-Jun action pattern suggests. (ofac.treasury.gov)
As of Wednesday, July 1, 2026, this market is mostly about what has already happened: the resolution window runs from January 1, 2026 through August 1, 2026, so only July 1-August 1, 2026 remains unresolved. I anchored on OFAC’s official 2026 “Sanctions List Updates” index pages covering the relevant notices from January 2 through June 30, 2026, then spot-counted the underlying Recent Actions notices themselves rather than relying on secondary summaries. (ofac.treasury.gov)
June alone was clearly heavy. From the official notices I manually counted: June 30 = 11 additions (2 individuals, 9 entities); June 26 = 8; June 25 = 5; June 22 = 9; June 18 = 8; June 11 = 1; June 5 = 16; June 4 = 10; and June 2 = 9. June 23 was also a very large package: the notice excerpts I reviewed show at least 9 individuals and well over two dozen entities, so June as a whole is comfortably above 100 additions even before July is considered. I excluded vessels and unrelated administrative changes when reading the notices, consistent with the question’s rules. (ofac.treasury.gov)
For the earlier months, the official index pages show many addition-bearing notices in February-May, a lighter March, and only a small number in January. My bottom-up estimate by month is roughly Jan ~15, Feb ~55, Mar ~20, Apr ~60, May ~85, and Jun ~110, which implies a realized January-June subtotal near 345. That subtotal is uncertain because I did not fully hand-tabulate every mixed notice in February-May by ENT_NUM, but it is consistent with the observed cadence and with how large the clearly countable June notices already are. (ofac.treasury.gov)
For the remaining July 1-August 1 period, my base case is another ~35-75 additions, centered around the low-50s. The main upside risk is that OFAC can release a single large Russia/Iran/Cuba/TCO package that adds dozens of people and entities at once, as June demonstrates; the main downside risk is a quieter month dominated by removals, updates, and non-SDN actions. Combining those scenarios gives me a central forecast around 400 total additions, with most probability mass in the low-300s through low-500s and only a thin tail above 700. (ofac.treasury.gov)
OFAC’s own archive confirms that 2026 SDN changes are being tracked cumulatively, and the 2026 sanctions-update pages show a dense run of designation notices from January 13, 2026 through June 30, 2026 across Iran, counterterrorism, counternarcotics, Cuba, DRC, Sudan, cyber, and other programs. That matters because by July 1, 2026, most of the resolution window has already elapsed, so the final answer is driven much more by what has already happened than by pure forward uncertainty. (ofac.treasury.gov)
The recent official notices are also large in absolute terms. Explicit counts in official Treasury material include: June 30 (2 Mexican nationals and 9 entities = 11), June 26 (8 individuals/entities), June 25 (Gasabo Gold, Kalima, Kayobotsi, Bugambira Mines, Wolfram Mining, and Rwinkwavu Mining = 6), June 23 (9 individuals and 26 entities = 35 in the Prince Group action), June 22 (3 individuals and 6 entities = 9), June 10 (9 individuals/entities), June 5 (a network that, in the designation text shown, amounts to 2 individuals and 5 entities, with vessels also discussed separately), June 2 DRC (2 commanders), June 2 Iran digital-asset action (8 people/entities in the designation text), and April 28 (35 entities and individuals). (home.treasury.gov)
Using those explicit-count notices plus conservative hand estimates for the smaller January-May designation notices whose snippets/pages I reviewed but did not fully machine-tally to unique ENT_NUM, I infer that the January 1-June 30 subtotal is already in roughly the high-300s to low-400s. That is my inference from the official notices, not an official OFAC total, and the main residual counting uncertainty is alias/ENT_NUM deduplication plus the question’s exclusion for administrative migrations/harmonizations. (ofac.treasury.gov)
For the remaining period, only July 1, 2026 through August 1, 2026 is still open. The pace in late April, May, and June shows that another medium or even large package is plausible, especially in Iran-, CT-, TCO-, or Cuba-related programs, but the remaining calendar time is short enough that the final number is unlikely to move by hundreds. My base case is roughly another 20-80 additions after July 1, with upside if another Prince Group-/shadow-banking-scale package lands and downside if July is comparatively quiet. (ofac.treasury.gov)
Putting that together, my median forecast is in the mid-450s, with most probability mass roughly in the 360-560 range. I assign only a tiny tail above 700 and an effectively negligible chance of exceeding 1000 by August 1, 2026, because that would require a pace far above the already-heavy 2026 run rate despite only about one month remaining. (ofac.treasury.gov)
I start from the best monthly proxy I could verify quickly for January through May 2026: Hughes Hubbard reports that OFAC added 84 individuals/entities in January, 82 in February, 34 in March, 172 in April, and 164 in May, for a five-month total of 536. Those roundups separately identify blocked vessels, so they are directionally close to this market’s scope even though they are not the official resolver data. (hugheshubbard.com)
June was also clearly active on the official OFAC Recent Actions site. I can directly verify 10 additions on June 4 under the Cuba-related action (five individuals and five entities), one addition on June 11 (CUPET), eight additions on June 18, nine additions on June 22, 35 additions on June 23, eight additions on June 26, and 11 additions on June 30. Those seven June notices alone imply at least 82 additional individuals/entities, before counting the June 2, June 5, and June 25 notices. (lupicinio.com)
That gives a conservative floor of 618 additions through June 30 (= 536 from Jan-May plus 82 from the June notices just listed). Because June 2, June 5, and June 25 also contained designation actions, I think the true Jan-June total is probably not just 618 but rather somewhere in roughly the mid-640s to mid-660s, with about 650 as a reasonable working midpoint. I apply some uncertainty here because the market resolves on unique ENT_NUM additions and excludes administrative migrations and some redesignations, while monthly legal roundups are proxies rather than resolver-grade counts. (hugheshubbard.com)
The broader base rate supports a high final number. CNAS counted 1,764 persons added to the SDN List in 2025, with 1,322 of those added after January 20 under the second Trump administration; CNAS also defines person here as an individual or entity, excluding aircraft and maritime vessels. So a final August 1, 2026 figure in the high hundreds would be materially below the 2025 full-year total but still consistent with the administration’s demonstrated sanctioning capacity. (cnas.org)
For the forward-looking part, there are 32 calendar days left from July 1 through August 1 inclusive. A simple pace model using the January-May proxy implies about 107 additions per month (536/5), and late June did not look like a lull: OFAC posted sizable actions on June 18, 22, 23, 25, 26, and 30. My baseline is therefore another roughly 95 to 130 additions in the remaining window. I then add a fat right tail for the possibility of one unusually large sanctions package, because 2025 shows OFAC can operate at a much faster pace than the current half-year run rate. (hugheshubbard.com)
Putting that together, my forecast is centered in the high 700s, with a median around 770 and a mean in the same neighborhood. Most of my probability mass sits roughly between 700 and 880. I keep only a small tail above 1000, because getting there by August 1 would require a very large July shock from an already-elevated but still only roughly mid-650s starting point. (cnas.org)