OFAC Economic Sanctions Programs
The U.S. Treasury’s OFAC administers 30+ active economic sanctions programs targeting specific countries, regimes, and individuals. Our lawyers advise on all OFAC sanctions programs — from compliance to asset unblocking and SDN list removal.
OFAC economic sanctions programs are country- or activity-specific regulatory regimes administered by the U.S. Office of Foreign Assets Control. Each program targets a different country, regime, or threat category, and carries its own set of prohibitions, general licences, and civil penalty structures. As of 2026, OFAC administers over 30 active sanctions programs.
Major Active OFAC Sanctions Programs (2026)
| Program | Primary Target | Key Prohibitions | Established |
|---|---|---|---|
| Russia (RUSAL, EO 14024) | Russian government, oligarchs, financial sector | Financial services, energy, defense, technology | 2014 / expanded 2022 |
| Iran (IEEPA, ITSR) | Iranian government, IRGC, oil sector | Nearly all trade and financial transactions | 1979 |
| North Korea (NKSR) | DPRK government, weapons programs | Nearly all trade, financial, and service transactions | 2000 |
| Cuba (CACR) | Cuban government | Most trade, travel-related financial transactions | 1963 |
| Syria (SySR) | Assad government, armed groups | Most exports, services, financial transactions | 2004 |
| Venezuela (EO 13884) | Maduro government, state entities | Government-related transactions, gold, oil | 2015 / expanded 2019 |
| Belarus (BSAR) | Lukashenko government, security services | Financial services, certain exports | 2006 / expanded 2021 |
The Office of Foreign Assets Control under the U.S. Department of the Treasury implements some of the toughest international sanctions regimes in the world. Violating these requirements threatens companies and individuals with significant fines, asset freezes, and serious reputational damage.
Our team is ready to provide comprehensive legal support on OFAC sanctions issues. We will conduct a thorough audit to identify vulnerabilities in supply chains, contracts, and operations, develop effective compliance programs, prepare the necessary licenses, and protect your interests during inspections and investigations by regulatory authorities. We take into account the specifics of your business processes and offer optimal protection methods.
Types of economic sanctions
Economic sanctions are tools of foreign policy that allow states and international organizations to exert pressure on other countries or specific individuals without using direct military measures.
Office of Foreign Assets Control is responsible for the development, implementation, and enforcement of economic and trade sanctions that affect a wide range of areas: asset freezes, business restrictions, bans on the export or import of certain goods and technologies, blocking financial transactions, and much more. Violations of OFAC programs are fraught with large fines, administrative, and even criminal liability for companies and individuals under U.S. jurisdiction.
Sanctions by countries
The traditional format of sanctions is by countries, when restrictive measures are directed against a specific state. The reasons can vary: support for terrorism, violation of human rights, aggression against other countries, development of weapons of mass destruction, etc.
In certain cases, OFAC practically blocks any transactions, including export, import, and financial operations. Government accounts and assets under U.S. jurisdiction may be frozen. Some transactions require a special OFAC license (for example, the supply of humanitarian goods, medical equipment).
Non-compliance with country sanctions may result in being added to the SDN List (Specially Designated Nationals and Blocked Persons List), which effectively cuts off any business activity in the United States and interaction with the financial system in dollars.
Intellectual sanctions
Unlike general measures by countries, “intellectual” or “targeted” sanctions are aimed at specific entities:
- Individual private persons: politicians, businessmen, officials, suspects in corruption, terrorism, cybercrimes;
- Organizations: companies, banks, funds involved in illegal schemes or supporting undesirable regimes.
The goal of smart sanctions is to minimize harm to the civilian population. Unlike total sanctions, which can negatively affect the economy of the entire country, targeted measures strike key figures contributing to illegal activities.
As an example of intelligent sanctions, one can cite the blocking of assets of officials caught in corruption, denial of visas, prohibition of entry, and any business contacts.
Secondary sanctions
Secondary sanctions are not directed directly against the target but against third parties that interact with an entity already under sanctions. For example, if a bank in a third country continues to do business with a company on the SDN List, it may itself come under sanctions.
The most tangible consequence of secondary sanctions is the loss of access to dollar transactions and American markets. Since the US dollar and the US financial system dominate globally, most companies do not want to lose the ability to conduct dollar transactions. Being added to OFAC’s sanctions lists is extremely risky for any international corporation.
Sectoral sanctions
Such measures are introduced by OFAC concerning specific sectors of the economy of a particular country: energy, finance, defense industry, etc.
Access to long-term loans, technology supply, export/import of goods necessary for the sector (oil, gas, military industry) is prohibited or restricted.
Unlike targeted sanctions against specific individuals, sectoral measures impact an entire industry, blocking its development, access to financing, and technologies. They may indirectly affect ordinary citizens working in these industries, as well as partner companies in third countries.
If you need assistance in the field of sanctions compliance or have questions regarding interactions with OFAC-sanctioned counterparties, we are ready to provide professional support. Our company specializes in consulting and protecting the interests of clients worldwide, minimizing risks and ensuring full compliance with OFAC programs.
Which countries are under OFAC sanctions?
Country-Based Sanctions are comprehensive measures targeting entire countries, effectively restricting or prohibiting almost all economic operations and transactions involving U.S. citizens or companies under American jurisdiction.
Iran
The main reason for the imposition of sanctions is the development of the nuclear program. Iran is also accused of sponsoring terrorist groups. In addition, the country is criticized for suppressing protests, restricting freedom of speech, discrimination against women, and national minorities.
American banks are prohibited from conducting transactions with Iranian banks and organizations listed in sanction lists. Funds and property of Iranian state structures and representatives are blocked.
A nearly complete ban on the supply of oil, technologies, and industrial equipment to the USA from Iran. Certain exceptions (licenses) apply to humanitarian goods, food, and medicine.
Global companies fear secondary sanctions, so they avoid working with Iran; this slows the growth of infrastructure projects. Iran cannot fully bring oil to the global market, which deprives the state budget of its main share of revenue. The currency is depreciating, import prices are rising, production and trade are shrinking.
Central African Republic
The reason for the imposition of sanctions is the prolonged civil conflict. Since 2012, the CAR has been in a state of armed confrontation between various groups. A large number of war crimes, ethnic violence, and crime associated with resource smuggling. Diamonds, gold mining, and other resources are used to finance armed groups.
Officials and groups involved in violence and corruption in the CAR are added to sanctions lists, their assets are frozen. The US prohibits the supply of weapons, as well as high-tech products without special licenses. Financial transactions are also restricted to prevent the financing of armed groups.
Syria
Since 2011, an armed conflict has been ongoing in Syria between government forces and various rebel groups. The Syrian regime is accused of aiding radical formations. The use of chemical weapons, war crimes, and mistreatment of the civilian population have also become reasons for the imposition of sanctions.
OFAC introduced a comprehensive blockade against the state: an almost complete ban on trade with Syrian state structures, including the oil and financial sectors. Any assets of the Syrian government under U.S. jurisdiction are blocked. Secondary sanctions have also been imposed on companies cooperating with Syria’s oil and gas industry or military-industrial complex.
Turkey
Turkey faced restrictions due to the purchase of S-400 missile defense systems, which the United States regarded as a violation of the CAATSA regime. Additionally, Ankara encountered sanctions for military operations in northern Syria, which, according to the United States, could contribute to destabilizing the region.
Targeted sanctions are mainly directed against specific Turkish state structures, military, and officials involved in arms procurement or actions in Syria. There are also restrictions in the financial sector: bans on issuing loans to certain Turkish enterprises, restrictions on the export of high-tech military products.
Turkey is a member of NATO, but sanctions from the United States overshadow allied relations and reduce the volume of potential joint projects in the defense industry.
Cuba
Since the 1960s, the United States has imposed an embargo on trade with Cuba due to Castro’s communist regime and suspicions of supporting terrorism. Cuba is accused of repressing the opposition and restricting freedom of expression.
Almost all trade with Cuba is prohibited (with the exception of licensed medical and agricultural goods). U.S. citizens are prohibited from tourist visits to Cuba, only trips under limited categories are allowed. Cuban state assets in the U.S. remain frozen.
North Korea
The DPRK conducts nuclear tests and launches ballistic missiles, ignoring UN resolutions. The country’s isolation and the repressive nature of the regime raise serious concerns.
Banks and companies in the United States are prohibited from having any business contacts with North Korean entities, except in specially licensed cases. There is also a ban on trade, virtually a complete taboo on the export or import of goods from the DPRK. Any foreign company cooperating with the DPRK in key sectors also risks falling under U.S. sanctions.
To avoid violations, companies and individuals should keep their finger on the pulse of events, regularly check updates to OFAC sanctions lists, and, if necessary, seek professional advice in the field of sanctions compliance.
Contact OFAC Lawyer
Due to different and selective sanctions programs, U.S. individuals and businesses may inadvertently find themselves in violation of OFAC regulations. Compliance with these sanctions is crucial to avoid significant legal and financial repercussions. Whether you are dealing with country-based sanctions, list-based sanctions, secondary sanctions, or sectoral sanctions, consulting with an experienced OFAC lawyer can provide invaluable guidance and support.
Engaging with an OFAC lawyer is a proactive step to ensure that your business activities remain compliant with complex sanctions regulations. With Sanctions Lawyers you can navigate the complexities of OFAC sanctions with confidence and reduce the risk of costly violations. Whether you are dealing with potential compliance issues or planning future ventures, an OFAC lawyer can provide the guidance and support you need.
Don’t wait until it’s too late. Contact an OFAC lawyer today to safeguard your business and ensure compliance with all relevant sanctions programs.
Frequently Asked Questions
What are OFAC economic sanctions programs?
OFAC economic sanctions programs are country-specific or thematic regulatory frameworks that restrict or prohibit transactions involving designated nations, entities, or individuals. Each program is established by executive order or statute and targets specific foreign policy or national security concerns. Current major OFAC programs include sanctions against Iran, Russia, Cuba, North Korea, Syria, Venezuela, and Belarus, as well as thematic programs targeting terrorism, narcotics trafficking, and cyberattacks. Each program has its own specific prohibitions, general license authorizations, and penalty provisions.
Who must comply with OFAC sanctions programs?
All U.S. persons — including U.S. citizens and residents wherever located, U.S. companies and their foreign branches, and any person or entity within U.S. territory — must comply with all applicable OFAC sanctions programs. Foreign companies are also subject to OFAC jurisdiction when they transact in U.S. dollars, involve U.S. financial institutions, or engage U.S. persons. Foreign subsidiaries of U.S. companies must comply with most OFAC programs regardless of their location.
How do I check if a country or company is subject to OFAC sanctions?
You can check OFAC sanctions exposure through several sources: the OFAC SDN list and Consolidated Sanctions List at sanctionssearch.ofac.treas.gov, OFAC country-specific pages listing active programs and prohibitions, and OFAC general license publications for each program. However, sanctions analysis requires more than a simple list check — it includes ownership screening (50-percent rule), jurisdictional analysis, and transaction-type review. Our attorneys provide comprehensive sanctions screening and compliance opinions tailored to your specific transaction.
What is the difference between comprehensive and targeted OFAC sanctions?
Comprehensive OFAC sanctions programs (such as those against Cuba, Iran, and North Korea) broadly prohibit virtually all transactions with the targeted country, its government, and nationals. Targeted or “smart” sanctions programs designate specific individuals and entities to the SDN list while leaving broader trade with the country largely unrestricted. Many countries face both — for example, Russia is subject to both broad sector sanctions and individual SDN designations. The applicable restrictions depend on the specific transaction, parties, and goods involved.
How often does OFAC update its sanctions programs?
OFAC updates its sanctions programs continuously. SDN list additions, removals, and amendments can occur multiple times per week. General license authorizations are issued and amended as geopolitical circumstances change. New executive orders can establish or expand entire sanctions programs with immediate effect. Companies should subscribe to OFAC alerts and implement automated screening systems that update in real time. Our attorneys monitor all OFAC program changes and advise clients on how regulatory updates affect their existing operations and transactions.