OFAC — the Office of Foreign Assets Control at the U.S. Treasury — currently maintains comprehensive embargoes against three countries: Cuba, Iran, and North Korea. Certain occupied regions of Ukraine are covered by the same near-total prohibitions. A much longer list of countries, including Russia, faces targeted or sectoral sanctions that stop short of a full embargo but still put most transactions off-limits for U.S. persons. The set of OFAC sanctioned countries shifts as foreign policy changes, most recently with the removal of comprehensive sanctions on Syria in mid-2025.
Countries Under Comprehensive Embargo
Comprehensive sanctions are the most severe category. Under these programs, U.S. persons cannot export goods, provide services, process payments, or make investments involving the sanctioned country unless OFAC has issued a specific or general license authorizing the activity. As of 2026, three countries are subject to full comprehensive embargoes: Cuba, Iran, and North Korea.1Office of Foreign Assets Control. Sanctions Programs and Country Information
Restrictions also cover certain occupied regions of Ukraine. Executive Order 14065, issued in February 2022, imposed comprehensive-style prohibitions on the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions, along with any additional regions the Secretary of the Treasury designates. The order bars new investment, imports from, and exports to these covered regions by U.S. persons.2Federal Register. Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to Continued Russian Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine Crimea has been under comprehensive sanctions since 2014. The Zaporizhzhia and Kherson regions, despite being partially occupied by Russia, are not currently designated as covered regions under this framework.
Syria Is No Longer Comprehensively Sanctioned
Until mid-2025, Syria was on this list. After the fall of the Assad regime in late 2024, the U.S. recalibrated. On June 30, 2025, President Trump signed Executive Order 14312, revoking six executive orders that had formed the backbone of the Syria sanctions program and terminating the underlying national emergency declaration. By August 2025, the Syrian Sanctions Regulations were formally removed from the Code of Federal Regulations.3U.S. Department of State. Syria Sanctions Former President Bashar al-Assad and other individuals remain sanctioned under separate authorities, but Syria as a country is no longer under a comprehensive embargo. If you are working from older guidance, treat Syria references with caution.
Russia: Extensive but Not Comprehensive
Russia occupies an unusual position. It is not under a single comprehensive embargo like Cuba or North Korea, but the overlapping web of targeted, sectoral, and blocking sanctions imposed since 2014 is so extensive that many transactions with Russia are effectively off-limits. The sanctions draw authority from multiple executive orders, with E.O. 14024 serving as a particularly broad tool that allows the Treasury Secretary to block any person operating in designated sectors of the Russian economy, including financial services, technology, defense, and energy.4Office of Foreign Assets Control. Russian Harmful Foreign Activities Sanctions
The Sectoral Sanctions Identifications (SSI) List targets persons operating in Russia’s financial services, energy, and defense sectors under E.O. 13662. Entities on the SSI List face restrictions on specific types of debt and equity transactions rather than a total asset freeze.5Office of Foreign Assets Control. Ukraine-/Russia-related Sanctions Because Russia’s sanctions come from multiple overlapping programs, compliance requires checking several lists and authorities, not just asking whether Russia is “on the list.”
Why the Country List Doesn’t Tell the Whole Story
Most of OFAC’s enforcement power doesn’t flow from country-wide embargoes. Targeted sanctions apply to specific individuals, companies, and vessels wherever they are in the world. The centerpiece is the Specially Designated Nationals and Blocked Persons List (SDN List), which includes parties connected to sanctioned governments, terrorism, narcotics trafficking, weapons proliferation, and other threats. When someone lands on the SDN List, every U.S. person must immediately freeze any property or interests in property belonging to that party.6U.S. Department of the Treasury. Specially Designated Nationals (SDNs) and the SDN List
The freeze is absolute. Blocked assets cannot be transferred, withdrawn, paid out, or otherwise dealt with until OFAC provides specific instructions or issues a license. No transaction of any kind with an SDN is permitted for U.S. persons, direct or indirect.
The 50 Percent Rule
OFAC’s 50 Percent Rule extends blocking obligations to any entity owned 50 percent or more, in the aggregate, by one or more blocked persons, even if that entity doesn’t appear on the SDN List by name. If Blocked Person A owns 25 percent of a company and Blocked Person B owns another 25 percent, the company is blocked. Ownership interests are aggregated across different sanctions programs.7Office of Foreign Assets Control. Entities Owned by Blocked Persons (50% Rule) A company with no obvious connection to sanctions can be blocked through layers of indirect ownership that only careful due diligence uncovers.
Other OFAC Lists
OFAC maintains several additional lists that carry their own restrictions. To simplify screening, OFAC publishes a Consolidated Sanctions List bundling the non-SDN lists into a single searchable dataset:8Office of Foreign Assets Control. OFAC Consolidated and Other Sanctions Lists Page
- Sectoral Sanctions Identifications List (SSI): entities in designated sectors of Russia’s economy, subject to restrictions on certain debt and equity transactions.
- Foreign Sanctions Evaders List (FSE): foreign persons who have facilitated deceptive transactions for sanctioned parties.
- Correspondent Account or Payable-Through Account Sanctions List (CAPTA): foreign financial institutions subject to restrictions or prohibitions on maintaining correspondent or payable-through accounts in the United States.
- Non-SDN Chinese Military-Industrial Complex Companies List (NS-CMIC): Chinese companies connected to China’s military-industrial complex, subject to investment restrictions on U.S. persons.
- Non-SDN Menu-Based Sanctions List (NS-MBS): persons subject to specific sanctions measures selected from a defined menu of options.
Screening only against the SDN List and ignoring these other lists is a common compliance gap.
Who Has to Comply
Primary sanctions bind “U.S. persons.” The definition is broad: any U.S. citizen regardless of where they live, any permanent resident alien (green card holder), any entity organized under U.S. law including its foreign branches, and any person physically present in the United States.9eCFR. 31 CFR Part 594 Subpart C – General Definitions A U.S. bank’s branch office in London must comply with OFAC sanctions just as its headquarters does. A foreign tourist visiting New York also becomes a U.S. person for sanctions purposes during their stay.
Secondary sanctions work differently. They target foreign companies and banks by threatening to cut off their access to the U.S. financial system if they do business with sanctioned parties. A European bank processing payments for an Iranian entity, for example, could face being shut out of dollar-clearing and U.S. correspondent banking relationships. The foreign person doesn’t technically violate U.S. law, but the economic consequences of losing U.S. market access create pressure to comply voluntarily.
When Transactions Can Still Be Authorized
Not every transaction touching a sanctioned country is automatically illegal. OFAC provides several safety valves.
General Licenses
General licenses authorize entire categories of transactions without requiring anyone to submit an application. OFAC publishes these on its website, and they typically cover humanitarian necessities: food, agricultural commodities, medicine, medical devices, and replacement parts for medical equipment. Other common categories include official U.S. government business, activities of certain international organizations, and humanitarian work by nongovernmental organizations.10Office of Foreign Assets Control. General Licenses If your transaction falls within a general license, you can proceed without filing anything, but document your reliance on the specific license in case questions arise later.
Specific Licenses
When no general license covers your situation, you can apply to OFAC for a specific license authorizing a particular transaction. Applications must be submitted electronically through OFAC’s licensing portal.11eCFR. 31 CFR 501.801 – Licensing Processing can take several months, and approval is never guaranteed. OFAC will not issue a specific license for a transaction that a general license already covers, so check the general licenses first.
Informational Materials
Under what is commonly called the Berman Amendment, OFAC sanctions do not apply to the import or export of informational materials such as books, films, artwork, news reports, music, and photographs, regardless of the country involved. The exemption applies to materials that are fully created and already exist at the time of the transaction.12eCFR. 31 CFR 560.210 – Exempt Transactions It does not cover paying advances for materials not yet created, hiring someone in a sanctioned country to produce new content, or providing marketing and consulting services related to those materials.
What Violations Cost
Early in 2026 alone, OFAC settled cases totaling nearly $5.5 million across two enforcement actions.13Office of Foreign Assets Control. Civil Penalties and Enforcement Information
Civil penalties can be imposed on a strict liability basis. OFAC does not need to prove you knew about the sanctions or intended to violate them. Under the International Emergency Economic Powers Act (IEEPA), the statutory maximum civil penalty per violation is the greater of $250,000 or twice the value of the underlying transaction.14Office of the Law Revision Counsel. 50 USC 1705 – Penalties That $250,000 base figure is adjusted annually for inflation; recent adjustments have pushed the per-violation cap above $377,000.15eCFR. 15 CFR Part 6 – Civil Monetary Penalty Adjustments for Inflation For high-value transactions, the “twice the transaction value” formula can produce penalties far larger than the base amount.
Criminal prosecution requires proof that the violation was willful. A willful violation under IEEPA can result in a fine of up to $1,000,000 per violation. Individuals face up to 20 years in federal prison, or both the fine and imprisonment.
In April 2024, the 21st Century Peace through Strength Act extended the statute of limitations for both civil and criminal OFAC violations from five years to ten years. The new ten-year window applies to any violation that occurred after April 24, 2019.16Federal Register. Reporting, Procedures and Penalties Aging transactions cannot be assumed safe from scrutiny.
If you discover a violation, disclosing it to OFAC before the agency finds it on its own can substantially reduce your penalty. For non-egregious violations, voluntary self-disclosure cuts the base penalty to one-half of the transaction value. For egregious violations, it reduces the base penalty to one-half of the applicable statutory maximum. Substantial cooperation during the investigation can reduce the penalty further.17Legal Information Institute. 31 CFR Appendix A to Subpart F of Part 501 – Economic Sanctions Enforcement Guidelines The difference between a self-disclosed penalty and one OFAC imposes after catching the violation independently can be significant.