US Embargoed Countries: List, Prohibitions, and Penalties

The United States currently maintains comprehensive embargoes against Cuba, Iran, North Korea, Russia, and the Russian-occupied Ukrainian regions of Crimea, Donetsk, Luhansk, Zaporizhzhia, and Kherson. These are the U.S. embargoed countries and territories where nearly every trade, financial, and service transaction is prohibited by default. Syria was on this list until July 1, 2025, when President Trump revoked the underlying executive orders and OFAC removed the Syrian Sanctions Regulations from the Code of Federal Regulations, although sanctions still apply to specific individuals tied to the former Assad regime, human rights abuses, and terrorism.¹

The Current Embargo List

A comprehensive embargo sets a default rule: any transaction with the territory is prohibited unless the U.S. government has specifically authorized it. The programs currently in force cover:

Cuba. The longest-standing U.S. embargo, in place since the early 1960s. The Cuban Assets Control Regulations prohibit virtually any transaction in which Cuba or a Cuban national has an interest, including transfers of credit, payments through banking institutions, and foreign exchange transactions.²
Iran. The Iranian Transactions and Sanctions Regulations ban both the import of Iranian-origin goods into the United States and the export of American goods, technology, or services to Iran, whether directly or through a third country.³
North Korea. Sweeping restrictions cover trade, financial services, and nearly all economic engagement with North Korean persons and entities.
Russia. Initially subject to targeted sanctions after its 2014 intervention in Ukraine, Russia’s sanctions have expanded dramatically since 2022 and now function as comprehensive restrictions across broad sectors of the Russian economy.
Occupied regions of Ukraine. Crimea, Donetsk, Luhansk, Zaporizhzhia, and Kherson are subject to comprehensive restrictions similar to those applied to the countries above.⁴

Syria’s 2025 removal shows that embargo status can change. If you are relying on older guidance, check the current OFAC program list before assuming a country is still restricted.

How Comprehensive Embargoes Differ From Targeted Sanctions

The comprehensive versus targeted distinction shapes how you approach any transaction. A comprehensive embargo blocks almost every commercial interaction with the entire territory. You cannot buy goods produced there, sell goods into the country, process payments through its banks, or provide services to its residents without specific authorization. The scope reaches every sector, from energy and agriculture to banking and manufacturing.

Countries like Venezuela and Myanmar face targeted sanctions instead. Regular commerce with the broader economy can continue, so long as you avoid the specific people, entities, and sectors the government has designated. A U.S. company could sell consumer goods to a Venezuelan business, for example, but could not process a payment involving a designated Venezuelan official.

The practical effect: comprehensive embargoes require you to prove a transaction is allowed; targeted sanctions require you to confirm it isn’t blocked. With the five embargoed jurisdictions, the starting assumption is always no.

What Is Prohibited

The prohibitions reach further than most people expect. The main categories of restricted activity include:

Importing goods or services. Bringing anything of embargoed-country origin into the United States is illegal, whether you bought it directly or through an intermediary.
Exporting goods, technology, or services. Shipping American products, software, or technical know-how to an embargoed country is prohibited. This includes indirect exports routed through third countries when you know or have reason to know the final destination.
Financial transactions. Processing payments, extending credit, opening accounts, or guaranteeing any transaction that benefits a sanctioned country or its nationals violates the embargo. Transactions denominated in U.S. dollars can trigger these rules even when both parties are outside the United States, because dollar-denominated transfers typically clear through American correspondent banks.
Services. Providing consulting, technical support, training, or any professional service to entities in embargoed territories is prohibited.

A freelance software developer who takes on a client from an embargoed country has violated the embargo, even if the payment never touches a U.S. bank. An American company whose foreign subsidiary quietly trades with Iran has a serious problem.

Cryptocurrency and Digital Assets

Sanctions apply to cryptocurrency the same way they apply to any other property. OFAC has stated its programs are not technology-specific, so blockchain transactions carry the same legal obligations as wire transfers or cash deals.⁵ An exchange that identifies a wallet address associated with a sanctioned person or jurisdiction must block the assets, prevent transfers, and report the blocked property to OFAC within 10 business days.

Travel

Cuba is the clearest example. Tourist travel by U.S. persons is prohibited by statute. Americans can only travel there under one of 12 categories authorized by OFAC general licenses, which include family visits, journalistic activity, humanitarian projects, religious activities, educational activities, and support for the Cuban people.⁶ Travelers must qualify under the specific conditions of their category and should keep records documenting eligibility.

Travel to North Korea is restricted under both sanctions law and a separate State Department passport restriction. For Iran, the embargo prohibits spending money on goods or services in the country, which effectively blocks most travel even without a formal ban. Any trip to a comprehensively embargoed country needs legal analysis before you book a flight.

Who the Rules Apply To

The core restrictions apply to any “U.S. person.” That term covers American citizens and permanent residents anywhere in the world, anyone physically present in the United States, all entities organized under U.S. law, and the foreign branches of American companies. Some programs also extend to foreign subsidiaries owned or controlled by a U.S. parent. A citizen living in London or Tokyo faces the same legal exposure as someone in New York.

Screening Against the SDN List

OFAC maintains the Specially Designated Nationals and Blocked Persons List, which identifies people and entities whose assets must be blocked and with whom U.S. persons cannot deal. The SDN list applies across all sanctions programs, not just comprehensive embargoes. A designated person becomes radioactive in the American financial system: assets frozen, transactions prohibited.

OFAC offers a free online search tool, though it cautions that the tool alone does not constitute adequate due diligence.⁷ The Commerce Department’s Bureau of Industry and Security maintains a separate Entity List, and exporters must screen against that list before shipping goods.

Penalties for Violating an Embargo

OFAC enforces on a strict liability basis. You can face civil penalties even if you had no idea you were doing anything wrong.⁸ Ignorance is not a defense. If your company processes a payment that benefits a sanctioned entity, OFAC can penalize you regardless of intent.

OFAC civil penalties. Up to $250,000 per violation (before annual inflation adjustments) or twice the value of the underlying transaction, whichever is greater. After inflation adjustments, the per-violation cap has risen above $350,000. For large transactions, the “twice the value” alternative can produce penalties in the millions.⁹
BIS civil penalties. Up to $374,474 per violation as of the most recent inflation adjustment, or twice the value of the transaction, whichever is greater. BIS can also revoke a company’s export privileges entirely.¹⁰
Criminal penalties. Willful violations of either IEEPA or the Export Control Reform Act carry fines up to $1,000,000 and imprisonment up to 20 years for individuals.⁹¹¹

Recent OFAC enforcement actions in 2026 have produced individual settlements exceeding $3.7 million and corporate settlements exceeding $1.7 million.¹² The government’s window to bring cases is also longer now. In 2024, Congress extended the statute of limitations for civil and criminal violations of IEEPA and the Trading with the Enemy Act from five years to ten years.¹³

Licenses and Narrow Exceptions

Not every interaction with an embargoed country is automatically illegal. The government authorizes exceptions through two types of licenses.

A general license is a standing authorization written into the regulations that permits specific categories of transactions without an application. These typically cover humanitarian activities like shipping food and medicine, certain telecommunications and internet services, and informational materials. Cuba’s 12 authorized travel categories work this way. So do certain exports of agricultural commodities, though Cuba requires payment in cash before goods ship.¹⁴ General licenses authorize exactly what they describe and nothing more. Miss a condition and you’re back in prohibited territory.

A specific license is an individual authorization you apply for when no general license fits. You submit a formal application to OFAC describing the transaction, the parties, and the business justification. Processing takes months, approval is never guaranteed, and any grant is narrow and time-limited. Straying from the terms is treated the same as violating the embargo itself.

Why Foreign Companies Care: Secondary Sanctions

Secondary sanctions target foreign companies and individuals who have no direct U.S. nexus but engage in significant transactions with sanctioned countries. The threat is loss of access to the American financial system and marketplace, which most international businesses cannot afford. A foreign company that provides material support to a person on the SDN list can itself be designated, effectively freezing it out of any transaction touching the United States.

These measures have been used most aggressively in connection with Iran, Russia, and North Korea. U.S. embargoes therefore cast a much wider shadow than their text suggests. Companies headquartered in allied nations routinely screen counterparties to avoid secondary exposure.

Compliance and Self-Disclosure

If your business handles international transactions, sanctions compliance is not optional. The baseline is screening every counterparty against the SDN list and the BIS Entity List before processing transactions, keeping written procedures, and training employees who handle cross-border payments or shipments.

OFAC extended its recordkeeping requirement from five to ten years in March 2025, aligning it with the extended statute of limitations.¹³ Any entity holding blocked property must file an Annual Report of Blocked Property through OFAC’s online reporting system, and rejected transactions must be reported as well.¹⁵

If you discover a potential violation, voluntary disclosure to OFAC is one of the strongest mitigating factors in the penalty framework. A qualifying disclosure can reduce the base civil penalty by up to 50 percent. To qualify, the disclosure must be truthful, complete, and submitted before the government opens an inquiry. OFAC launched an online portal for voluntary self-disclosures in February 2026. BIS similarly encourages voluntary disclosure, and choosing not to disclose a significant violation you’ve discovered is treated as an aggravating factor that increases penalties.¹⁶

Strict liability enforcement, a ten-year lookback, and penalties reaching into the millions make embargo compliance one of the highest-risk areas in international business. If any part of your operation touches Cuba, Iran, North Korea, Russia, or the occupied Ukrainian territories, get the transaction reviewed before it happens rather than after.

1
Office of Foreign Assets Control. Syria Sanctions – Inactive and Archived
2
eCFR. 31 CFR Part 515 – Cuban Assets Control Regulations
3
eCFR. 31 CFR Part 560 – Iranian Transactions and Sanctions Regulations
4
Office of Foreign Assets Command. Ukraine-/Russia-related Sanctions
5
Office of Foreign Assets Control. Sanctions Compliance Guidance for the Virtual Currency Industry
6
U.S. Embassy in Cuba. Traveling to Cuba
7
U.S. Department of the Treasury. Sanctions List Search
8
Office of Foreign Assets Control. FAQ 65
9
Office of the Law Revision Counsel. 50 USC 1705 – Penalties
10
Bureau of Industry and Security. Enforcement Penalties
11
Office of the Law Revision Counsel. 50 USC 4819 – Penalties
12
Office of Foreign Assets Control. Civil Penalties and Enforcement Information
13
Office of Foreign Assets Control. Federal Register – OFAC Recordkeeping Requirements Final Rule
14
Office of Foreign Assets Control. Cuba Sanctions
15
Office of Foreign Assets Control. OFAC Reporting System
16
eCFR. 15 CFR 764.5 – Voluntary Self-Disclosure