Sanctions & Financial

OFAC Sanctions Defense

US sanctions reach further than most people expect — often catching non-US persons with only a limited American connection.

Direct answer: The US Treasury's Office of Foreign Assets Control (OFAC) administers and enforces US economic sanctions programmes. Its reach is often extraterritorial — a transaction routed through US dollars or a US financial institution can bring non-US persons within OFAC's jurisdiction, even where the underlying conduct occurs entirely outside the United States. Consequences range from blocked transactions to civil penalties and, in serious cases, criminal referral.
How OFAC Actually Reaches You

Understanding Extraterritorial Exposure

01

US Dollar Transactions

Transactions clearing through US dollars, even between two non-US parties, can bring OFAC jurisdiction into play.

02

Designated Parties Lists

OFAC maintains lists of sanctioned individuals, entities, and countries, with severe restrictions on dealing with anyone on them.

03

Secondary Sanctions Risk

In some programmes, dealing with a sanctioned party can itself trigger sanctions exposure, even without a direct US connection.

04

Licensing & General Licences

OFAC issues specific and general licences permitting otherwise-restricted transactions in defined circumstances.

Frequently Asked

Common Questions

Can OFAC really affect someone with no US citizenship or presence?

Yes — many OFAC programmes apply extraterritorially, particularly where US dollar transactions or US institutions are involved anywhere in the chain.

What should I do if a transaction is suddenly blocked?

Get a clear legal assessment of the specific designation and its actual reach before responding to the bank or OFAC directly.

Is OFAC exposure always a criminal matter?

Not necessarily — many matters are resolved through licensing applications or civil penalty processes, though wilful violations can escalate to criminal referral.

Facing OFAC Exposure or a Frozen Transaction?

Speak with us confidentially before responding to your bank or OFAC directly.