OFAC Sanctions: Who’s Really at Risk?

🔒Even non-U.S. companies can trigger U.S. sanctions – here’s how.

In today’s compliance landscape, it's no longer enough to just “not be American.” U.S. sanctions compliance reaches far beyond U.S. borders, and the Office of Foreign Assets Control (OFAC) has built a powerful enforcement machine ready to target anyone – from California to Copenhagen – if they step out of line.

Whether you're a compliance officer, consultant, or export manager, understanding how OFAC defines jurisdiction, enforces primary and secondary sanctions, and calculates penalties is essential. This blog is your go-to guide for understanding who’s really at risk, and what you can do to stay off the SDN list.

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Key Questions Covered in This Blog

• What is the difference between an OFAC designation and a sanctions enforcement action?

• What are the main OFAC lists, and what do they mean for businesses?

• What is a “U.S. nexus” and how does it create sanctions risk?

• Can non-U.S. companies be penalized under U.S. sanctions?

• How does OFAC determine penalties and decide when to prosecute?

• What factors can mitigate or aggravate OFAC enforcement actions?

“You don’t need to have a U.S. office to face U.S. sanctions. A single dollar transaction, routed via New York, can get you blacklisted.”— Arne Mielken, Managing Director, Customs Manager Ltd

Abbreviations Used In This Blog

• OFAC: Office of Foreign Assets Control (U.S. Treasury)

• SDN List: Specially Designated Nationals and Blocked Persons List

• IEEPA: International Emergency Economic Powers Act

• DOJ: U.S. Department of Justice

• OFSI: UK Office of Financial Sanctions Implementation

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What is the difference between an OFAC designation and a sanctions enforcement action?

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