The comprehensively OFAC sanctioned countries are Cuba, Iran, North Korea, and Syria — where virtually all transactions require an OFAC license. Russia, Venezuela, and Belarus face broad targeted sanctions but are not comprehensively sanctioned.
Comprehensively Sanctioned Countries (2026)
OFAC maintains two tiers of country-based sanctions: comprehensive embargoes and targeted programs. Comprehensive sanctions apply to Cuba, Iran, North Korea, and Syria — meaning that virtually all transactions involving these jurisdictions are prohibited for U.S. persons without a specific OFAC license. Understanding the difference is critical for OFAC compliance.
| Country | Sanctions Type | Key Prohibition | OFAC Program |
|---|---|---|---|
| Iran | Comprehensive | All trade, financial, tech | ITSR |
| Cuba | Comprehensive | All trade (CACR embargo) | CACR |
| North Korea | Comprehensive | All transactions | NKSR |
| Syria | Comprehensive | All trade and investment | SSR |
| Russia | Broad targeted | Energy, finance, defense | EO 14024+ |
| Venezuela | Targeted | PDVSA, government officials | EO 13884 |
| Belarus | Targeted | State enterprises, officials | EO 13405 |
Broad Targeted Sanctions: Russia, Venezuela, Belarus
Russia is subject to some of the most extensive targeted sanctions ever imposed by the United States, but it is NOT comprehensively sanctioned. Prohibitions focus on energy, defense, and financial sectors — including major banks, oligarchs, and state enterprises. Since February 2022, OFAC has issued dozens of executive orders and general licenses affecting Russia.
Venezuela faces targeted sanctions primarily directed at PDVSA (the state oil company), senior government officials, and the financial sector. Belarus sanctions target state-owned enterprises, the Lukashenko regime, and individuals involved in human rights abuses.
How to Check the OFAC Sanctions List
OFAC maintains multiple searchable lists at sanctions.ofac.treas.gov. The primary tool is the Consolidated Sanctions List (CSL), which includes the SDN list and all other OFAC lists. Businesses should screen all counterparties — not just country of incorporation, but also beneficial owners, ships, aircraft, and jurisdictions of operation.
Country-level sanctions are defined by program regulations, not just list entries. A transaction with a party in Cuba may be prohibited even if that party does not appear on the SDN list.
What Happens If You Transact with a Sanctioned Country?
Transacting with a comprehensively sanctioned country without a valid OFAC license is a strict-liability violation — meaning intent is not required for liability. Civil penalties can reach $1.3 million per transaction or twice the transaction value, whichever is greater. Criminal penalties under IEEPA can reach $1 million and 20 years imprisonment.
If you have conducted a potentially prohibited transaction, our OFAC sanctions attorneys can assess your exposure and advise on voluntary self-disclosure to reduce penalties by up to 50%. We represent clients in 40+ countries and handle all OFAC proceedings remotely. Request a free consultation.
Need an OFAC License for a Sanctioned Country?
OFAC issues specific and general licenses permitting otherwise-prohibited transactions. For humanitarian trade, journalistic activity, legal representation, and certain financial transactions, licenses are available. Our lawyers prepare and file OFAC specific license applications through the SNAP-R system on behalf of clients worldwide.