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OFAC Sanctions Programs

Which Type of OFAC Sanctions Program is Impacting You?

OFAC administers a variety of sanctions programs, the scope and contours of which depend upon the legal authority under which the program was imposed. Notwithstanding the variances, OFAC sanctions generally fall into one of two broad categories: comprehensive sanctions programs and targeted sanctions programs. Comprehensive sanctions programs target an entire country, geographic region, or economic sector. For example, there are comprehensive country-based sanctions prohibiting virtually all transactions between U.S. persons and Iran, Cuba, North Korea, the Crimea Region of Ukraine, etc. Targeted sanctions programs--sometimes referred to as list-based sanctions--are those that identify specific individuals, entities, or organizations that are engaged in a specific type of conduct or operate in a specific economic sector. For example, OFAC maintains sanctions programs targeting persons involved in international narcotics trafficking, terrorism, human rights abuses, public corruption, operating in the energy sector of the Russian Federation economy, operating in the shipping sector of the Iranian economy, operating in the oil sector of the Venezuela economy, etc.

Under these sanctions programs, there are also specific types of sanctions that can be imposed. The most common type of sanction imposed under an OFAC-administered sanctions program is a blocking. Blocking sanctions block or freeze all assets within the United States, that come within the United States, or in or that come within the possession or control of a U.S. person in which a sanctioned person who has had a blocking sanction imposed upon them maintains an interest. These sanctions also generally prohibit U.S. persons from providing any goods, services, or technology to those blocked parties, as well as from receiving any goods or services from them. There are also sanctions that impose trade-related restrictions on parties. Those prohibitions--most commonly found in country-based comprehensive sanctions programs--generally prohibit U.S. persons from receiving any goods or services from parties subject to these trade-related sanctions, as well as providing any goods or services to them. Finally, there are sectoral sanctions which impose limited restrictions upon U.S. persons' dealings with certain parties, such as dealings in new debt or new equity of those parties. The most common example of these types of sanctions are those targeting entities operating in certain economic sectors of the economy of the Russian Federation.

The above represent examples of some of the more common categories and types of sanctions. For more specific information on a particular sanctions programs, click on the links below: