The United States currently maintains comprehensive economic sanctions against six jurisdictions: Cuba, Iran, North Korea, Russia, Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine. Those countries sit at the top of the U.S. restricted countries list, but they are not the only places where cross-border business is limited. Separate federal programs also restrict defense exports to a wider group of countries, control sensitive dual-use technology on a country-by-country basis, block dealings with specific individuals wherever they live, and flag jurisdictions with weak financial oversight. Which rules apply depends on what you are shipping, who you are paying, and where the money or goods ultimately land.
The Six Comprehensively Sanctioned Jurisdictions
Comprehensive sanctions are the strictest tier and function as near-total economic embargoes. The Office of Foreign Assets Control (OFAC), a division of the U.S. Treasury, administers each program.1U.S. Department of the Treasury. Office of Foreign Assets Control The jurisdictions currently subject to comprehensive U.S. sanctions are:
- Cuba
- Iran
- North Korea
- Russia
- Syria
- The Crimea, Donetsk, and Luhansk regions of Ukraine
Each program has its own Executive Order and regulatory framework, so the exact scope of prohibited activity differs from country to country. Russia’s sanctions, for instance, have expanded rapidly since 2022 and include specific carve-outs that don’t exist in the older Cuba or Iran programs. Checking the OFAC program page for the specific country before engaging in any cross-border activity is the only reliable way to know what’s currently allowed.
What the Comprehensive Embargoes Prohibit
Under a comprehensive embargo, nearly every economic link between the United States and the sanctioned country is severed. The rules reach imports, exports, investment, and banking:
- Bringing goods, services, or technology from the sanctioned country into the U.S. is illegal, even if routed through a third country.
- Shipping American-origin products to the sanctioned country is prohibited, whether directly or through an intermediary.
- Buying equity in, or extending credit to, businesses located in the sanctioned territory is blocked.
- Banks cannot process payments to or from the sanctioned country, and individuals cannot transfer funds there without specific authorization.
The compliance burden falls on the individual or business, not on the government. If a shipment ends up in a sanctioned country because you didn’t screen the final destination, OFAC holds you responsible. The same applies to banking transactions routed through correspondent banks that touch a sanctioned jurisdiction. Most accidental violations happen exactly this way: a company deals with a legitimate-looking intermediary that turns out to be funneling goods or money into an embargoed country.
The SDN List: Restricted People, Not Just Restricted Places
Country lists are only half the picture. The Specially Designated Nationals and Blocked Persons List (the SDN List) names specific individuals and entities that are off-limits regardless of where they are located. OFAC publishes it, and it includes terrorists, narcotics traffickers, and entities owned or controlled by sanctioned governments.2U.S. Department of the Treasury. Frequently Asked Questions – Specially Designated Nationals and the SDN List Once someone is designated, their assets within U.S. jurisdiction are blocked immediately, and U.S. persons cannot deal with them in any way. That prohibition covers wire transfers, services, technology sharing, and delivering anything of value. Property in which an SDN holds any interest must be blocked and reported to OFAC within 10 business days.3eCFR. 31 CFR 501.603 – Reports on Blocked and Unblocked Property
The 50 Percent Rule
An entity doesn’t need to appear on the SDN List by name to be blocked. Under OFAC’s 50 Percent Rule, any company owned 50 percent or more, directly or indirectly, by one or more blocked persons is itself treated as blocked. The ownership stakes of multiple SDNs are aggregated: if two different SDNs each own 25 percent of a company, that company is blocked even though neither holds a majority stake on its own.4U.S. Department of the Treasury. Entities Owned by Blocked Persons – 50 Percent Rule OFAC calculates indirect ownership through the chain: if a blocked person owns 100 percent of Company A, and Company A owns 60 percent of Company B, then Company B is blocked. If Company A only owned 40 percent of Company B, it would not be. The blocked subsidiary won’t appear on any published list, so counterparties have to map ownership structures themselves.
Export Controls: A Different List for Sensitive Technology
Two other regulatory frameworks control the export of sensitive technology and military equipment. They don’t impose blanket embargoes; they require licenses for specific items going to specific destinations.
The Commerce Country Chart
The Bureau of Industry and Security (BIS) at the Department of Commerce controls dual-use items, meaning technology with both civilian and potential military applications, such as high-performance computing equipment or certain chemicals. The Commerce Country Chart, at 15 CFR Part 738, cross-references each item’s classification against the destination country to determine whether an export license is required.5eCFR. 15 CFR Part 738 – Commerce Control List Overview and the Country Chart A product that ships freely to one country may need a license for another depending on the export control reason involved, whether national security, missile technology, chemical weapons, or another category.
ITAR Proscribed Countries
The International Traffic in Arms Regulations (ITAR), administered by the State Department, control defense articles and services. Under 22 CFR 126.1, the following countries face an outright policy of denial for all defense-related exports: Belarus, Burma, China, Cuba, Iran, North Korea, Syria, and Venezuela.6eCFR. 22 CFR 126.1 – Prohibited Exports, Imports, and Sales to or From Certain Countries
An additional 16 countries face country-specific restrictions that may amount to a policy of denial depending on the circumstances: Afghanistan, the Central African Republic, Cyprus, the Democratic Republic of the Congo, Eritrea, Ethiopia, Haiti, Iraq, Lebanon, Libya, Nicaragua, Russia, Somalia, South Sudan, Sudan, and Zimbabwe.6eCFR. 22 CFR 126.1 – Prohibited Exports, Imports, and Sales to or From Certain Countries The restrictions cover military hardware, technical data, and training, and violations can result in debarment from future defense trade along with substantial fines.
The Deemed Export Rule
Export controls apply inside the country as well. Under the deemed export rule, sharing controlled technology with a foreign national inside the United States counts as an export to that person’s home country. If shipping the same technology abroad would require a license, sharing it with them here requires one too.7Bureau of Industry and Security. Deemed Export FAQs A university lab hiring a researcher from a restricted country, or a tech company onboarding an engineer from China, may need a deemed export license before granting access to controlled technical data. U.S. citizens, permanent residents, and protected persons under federal immigration law are exempt.
FATF Watchlists: Banking Friction, Not a Trade Ban
The Financial Action Task Force (FATF) is an intergovernmental body focused on money laundering and terrorist financing.8Financial Action Task Force. What We Do Appearing on a FATF list doesn’t make it illegal to do business with a country, but it makes transactions slower and more expensive.
The FATF High-Risk Jurisdictions Subject to a Call for Action, sometimes called the black list, currently names three countries as of the October 2025 update: North Korea, Iran, and Myanmar.9Financial Action Task Force. High-Risk Jurisdictions Subject to a Call for Action The FATF asks member countries to apply countermeasures, which in practice means banks apply enhanced scrutiny and may decline transactions entirely.
The Jurisdictions Under Increased Monitoring list, known as the grey list, is longer. As of the February 2026 update it includes 22 countries and territories: Algeria, Angola, Bolivia, Bulgaria, Cameroon, Côte d’Ivoire, the Democratic Republic of the Congo, Haiti, Kenya, Kuwait, Lao PDR, Lebanon, Monaco, Namibia, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, the British Virgin Islands, and Yemen.10Financial Action Task Force. Black and Grey Lists Financial institutions processing transactions involving these countries typically require extra documentation on the source of funds and beneficial ownership.
Humanitarian Exceptions Exist, With Conditions
Comprehensive sanctions don’t prohibit everything. OFAC issues general licenses that authorize specific categories of activity without case-by-case permission, and those licenses cover humanitarian needs like food, medicine, and medical devices. For Iran, transactions involving the sale of agricultural commodities, food, medicine, or medical devices are broadly exempt from sanctions unless the transaction involves persons designated in connection with terrorism or weapons proliferation.11U.S. Department of the Treasury. OFAC FAQ 637 General licenses also cover certain personal remittances, letting people send non-commercial funds to family members in places like Afghanistan.12U.S. Department of the Treasury. Selected General Licenses Issued by OFAC The key detail is that general licenses come with conditions. Sending food to Iran is legal; routing the payment through a designated bank is not.
Screening Tools and Penalties
The Consolidated Screening List (CSL), maintained by the International Trade Administration, is the practical starting point for anyone involved in cross-border transactions. It aggregates restricted-party lists from Commerce, State, and Treasury into a single searchable database that updates daily.13International Trade Administration. Consolidated Screening List A match doesn’t automatically mean the transaction is prohibited, but it triggers a due diligence obligation to check the underlying official list before proceeding.
The stakes for getting it wrong are high. Willful violations of U.S. sanctions carry criminal penalties of up to $1,000,000 in fines and up to 20 years in prison for individuals.14Office of the Law Revision Counsel. 50 USC 1705 – Penalties Civil penalties apply even without willful intent and can reach $377,700 per violation or twice the value of the underlying transaction, whichever is greater.15Federal Register. Inflation Adjustment of Civil Monetary Penalties A single shipment that touches multiple prohibited categories can generate stacked penalties. Businesses that discover a violation and disclose it voluntarily receive a 50 percent reduction in the base civil penalty amount; waiting for OFAC to find it first eliminates that discount.16U.S. Department of the Treasury. OFAC Self Disclosure
OFAC now requires records of any transaction subject to sanctions regulations to be kept for at least ten years after the transaction date, under a final rule effective March 21, 2025.17U.S. Department of the Treasury. OFAC Recordkeeping Final Rule A violation surfaced during an audit years after the fact can still generate enforcement action if the paperwork isn’t there to explain it.