US sanctions reach further than most people expect — often catching non-US persons with only a limited American connection.
Transactions clearing through US dollars, even between two non-US parties, can bring OFAC jurisdiction into play.
OFAC maintains lists of sanctioned individuals, entities, and countries, with severe restrictions on dealing with anyone on them.
In some programmes, dealing with a sanctioned party can itself trigger sanctions exposure, even without a direct US connection.
OFAC issues specific and general licences permitting otherwise-restricted transactions in defined circumstances.
Yes — many OFAC programmes apply extraterritorially, particularly where US dollar transactions or US institutions are involved anywhere in the chain.
Get a clear legal assessment of the specific designation and its actual reach before responding to the bank or OFAC directly.
Not necessarily — many matters are resolved through licensing applications or civil penalty processes, though wilful violations can escalate to criminal referral.
Speak with us confidentially before responding to your bank or OFAC directly.