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Last Updated 5/09/2008
The Office of Foreign Assets Control is an office of the Treasury Department. It is charged with implementation and enforcement of regulations to carry out the foreign policy of the United States. These regulations are complex, and vary widely with respect to different countries. Use the chart below as a general guide, but note the references in the chart to guides published by OFAC that reflect that office's official position.
| Affected Country or Entity | Summary of Sanctions | Special Notes |
Balkans - Entities that threaten the International Stabilization Efforts in the Western Balkans
Get the details | BLOCKING. All property and assets of designated persons are BLOCKED and may not be transferred, paid, exported, withdrawn, or otherwise dealt in.
Prohibited activity. The making or receiving by a U.S. person of any contribution or provision of funds, goods, or services to or for the benefit of a designated person is prohibited. In addition, any transaction by a U.S. person that evades or avoids or has the purpose of or attempts to violate these prohibitions and any conspiracy to violate the prohibitions is prohibited. | On May 29, 2003 all FRYM and BALKANS entries previously on the SDN list were deleted and 173 new BALKANS entries were substituted.
General License granted for legal representation at the International Criminal Tribunal for the former Yugoslavia
Details: License 1
Penalties: 20 years' imprisonment; $500,000 corporate and $250,000 individual fines. Administrative civil penalties up to $50,000 per violation. |
Belarus
| Assets Blocked As of June 19, 2006, all property and interests in property of persons listed in the OFAC SDN lists with a [BELARUS] designation are blocked, "and may not be transferred, exported, withdrawn, or otherwise dealt in.
Donations to or for the benefit of those same persons are prohibited.
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Burma (Myanmar)
Get the details | Prohibited Activity: New investment by U.S. persons on or after May 21, 1997 with the Government of Burma or other entities in Burma for the development of resources is prohibited. (Could include loans for those development purposes.)
Exportation of Financial Services to Burma. Generally speaking, the export of financial services to Burma is prohibited. That includes the transfer of funds, directly or indirectly, from the United States or by a U.S. person, wherever located, to Burma, and the provision to persons in Burma of insurance, investment, brokerage, banking or money services businesses; loans, guarantees, letters of credit or other extensions of credit; or the selling or redemption of traveler's checks, money orders and stored value.
Payments can be made for licensed or exempt transactions, such as diplomatic payments or payments for goods exported to Burma, but payments cannot be made from blocked accounts on the books of a U.S. bank. See OFAC's overview for details.
Accounts for Individuals in Burma. U.S. financial institutions can operate accounts for individuals in Burma, except for blocked parties. These accounts must be used only for personal transactions that are not otherwise prohibited, and no transfers may be made from these accounts directly or indirectly to Burma or for the benefit of persons residing in Burma unless authorized by 31 CFR 537.517.
| In addition, a U.S. person is prohibited from approving or supporting a foreign person's new investment in Burma and from purchasing shares in a third-country company whose profits are predominately derived from the economic development of resources in Burma.
The sale or purchase of goods or services to or from Burma is exempt from the sanctions under certain circumstances. (See detail.)
Several general licenses have been issued (the latest May 6, 2008). Most are designed to permit the winding down of transactions permitted prior to the most recent Executive Order, dated July 29, 2003.
On May 6, 2008, largely in response to losses of life and property damage in the wake of Cyclone Nagris, OFAC has issued General License No. 14, which allows nongovernmental organizations to engage in not-for-profit humanitarian or religious activities in Burma more easily. Specifically, General License No. 14 authorizes the exportation or reexportation of financial services to Burma in support of the not-for-profit humanitarian or religious activities in Burma of U.S. or third-country nongovernmental organizations. On May 9, 2008, OFAC announced that it had amended General Licence No. 14 to allow U.S. persons to make donations in support of not-for-profit humanitarian or religious activities in Burma, subject to certain conditions. This amended general license expands the authorization for a period of 120 days to allow funding to any organization or individual engaged in not-for-profit humanitarian or religious activities in Burma, subject to certain conditions.
Also on May 9, 2008, OFAC issued General License No. 15, to allow U.S. financial institutions to process transfers of funds, unlimited in amount, for noncommercial, personal remittances to or from Burma, or for or on behalf of an individual ordinarily resident in Burma, subject to certain conditions. Prior to the issuance of this general license, noncommercial, personal remittances to Burma were permitted only insofar as total remittances did not exceed $300 per Burmese household in any consecutive three-month period. This new general license includes no such limitation.
For details, see Burma Sanctions Guide.
Penalties: 20 years' imprisonment; $500,000 corporate and $250,000 individual fines. Administrative civil penalties up to $50,000 per violation. |
Côte d'Ivoire (Ivory Coast)
Get the details |
Prohibited Activity: Transactions are prohibited with persons designated in OFAC's list of SDNs and Blocked Persons with a descriptor of [COTED], and others.
Blocked. Any property of any Côte d'Ivoire SDN is blocked.
The Côte d'Ivoire sanctions were effective 2/8/2006.
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Penalties: Criminal fines up to $500,000 or twice the pecuniary gain per violation or an organization; up to $250,000 or twice the pecuniary gain per violation for individuals. Up to 10 years in prison. Civil penalties of up to $100,000 per violation. |
Cuba
Get the details | Blocking. Cuba Cuban assets, both government and private, are BLOCKED.
Financial dealings with Cuba are BLOCKED.
All property of Cuba, all Cuban nationals, and all Specially Designated Nationals (SDNs) of Cuba are BLOCKED.
An estate account becomes BLOCKED whenever a Cuban national is an heir or is the deceased.
Access to a safe deposit box is BLOCKED whenever a Cuban has an interest in the contents of the box.
Life insurance proceeds are blocked if the deceased is a Cuban resident.
| U.S. residents may send limited amounts of money to members of the remitter's immediate family (except certain government officials and certain members of the Cuban Communist Party), and to certain non-government organizations. Financial institution must obtain a Cuban Remittance Affidavit (an OFAC form) from the remitter prior to any transfer, and now must obtain specific OFAC authorization as remittance forwarders before providing such services.
Travel to Cuba is not authorized unless the traveler falls into a listed general category or has been granted a special license by OFAC. Effective June 30, 2004, restrictions on travel to Cuba are significantly tighter, and a prior license to bring back $100 in Cuban goods is eliminated, except for certain informational materials.
Penalties: 10 years in prison; $1 million in corporate and $250,000 individual fines; up to $55,000 per violation in civil penalties.
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Iran
Get the details | Rejected. Bank transactions relating to goods or services of Iranian origin or owned or controlled by the Government of Iran must be REJECTED.
New investments by U.S. persons, including commitments of funds or other assets, loans or any other extensions of credit in Iran or in property owned or controlled by the Iranian Government must be REJECTED.
Any commercial activity between a customer and a person in Iran or the Government of Iran must be REJECTED.
All accounts belonging to persons or entities in Iran or the Government of Iran must be REJECTED.
Any transaction involving trade in Iranian oil or petroleum products refined in Iran or which would benefit the Iranian oil industry must be REJECTED.
Beginning in April 2000, U.S. persons were authorized to purchase and import carpets and food products such as dried fruits, nuts and caviar for Iran.
Payments to Iran for services rendered by its government in connection with the overflight of Iran or emergency landing in Iran by aircraft owned by U.S. persons or registered in the U.S. are authorized.
U.S. Affiliates. U.S. persons (including financial institutions) with foreign affiliates may not permit the affiliate to do anything with regard to Iran that the U.S. person is prevented from doing directly. |
U.S. depository institutions may handle "U-turn transactions" that cover payments involving Iran that are by the order of a third country bank as long as an Iranian account is not debited or credited.
Banks may handle non-commercial family remittances involving Iran and non-commercial remittances involving humanitarian relief, provided the transfers are routed to or from non-U.S., non-Iranian offshore banks.
The institution must determine prior to processing any payment orders that they do not involve prohibited transactions.
Donations of articles intended to relieve human suffering are permitted.
A list of banks owned or controlled by the Government of Iran is provided.
Specific licenses. Nongovernmental organizations authorized by specific license or under the new provisions of the Iraqi Sanctions Regulations may conduct certain activities in Iran that are directly incidental to their authorized humanitarian activities in Iraq and conduct limited survey or assessment missions in Iran pertaining to the planning of or preparation for the provision of humanitarian support to the Iraqi people.
Bank Saderat transactions prohibited. Effective 9/8/2006, all transactions, direct or indirect, with or involving Bank Saderat are prohibited.
Bank Sepah transactions prohibited. Effective 1/9/07, all transactions, direct or indirect, with or involving Bank Sepah or Bank Sepah International Plc are prohibited.
Penalties: 20 years' imprisonment. Administrative fines up to $50,000 per violation.
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Iraq
Get the details.
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All transactions previously prohibited are now authorized, with certain exceptions. |
Exceptions:
All property and interests in property blocked as of May 23, 2003 are still blocked.
The export or re-export from a third country to Iraq of goods or technology must be authorized by the Department of Commerce.
Transactions dealing with Iraqi cultural property illegally removed since August 6, 1990 are not authorized.
Financial transactions with Iraq are allowed, except for those involving individuals and entities on OFAC's SDN list. The opening of correspondent accounts for Iraqi financial institutions is permitted.
Important Note: On 7/17/07, the White House issued an Executive Order adding a category of persons whose assets are to be blocked -- those who have undermined peace and stability in Iraq or U.S. efforts in that country. The effect of this order will be to permit OFAC to add persons fitting the description in the order to its SDN list.
Penalties for violating the Iraqi sanctions regulations: Up to 12 years in jail; up to $1 million in fines. Civil penalties up to $325,000 per violation.
Additional criminal penalties for violating related Executive Orders: up to 10 years in prison, $500,000 in corporate fines and $250,000 in individual fines. Civil penalties up to $11,000 per violation.
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Liberia
Get the details | BLOCKED:The assets of certain persons involved with the former Liberian regime headed by Charles Taylor are blocked. Donations to these persons are forbidden.
The importation of any "round log or timber product" from Liberia is forbidden.
The importation of any rough diamonds from Liberia, regardless of origin, is forbidden.
| On 5/23/2007, OFAC issued regulations at 31 CFR Part 593 implementing the 7/22/2004 Executive Order targeting the regime of Charles Taylor.
Section 593.510 of that regulation includes a general license for the importation of round log or timber products originating in Liberia, except in a transaction with any of the blocked parties related to the Taylor regime. |
Libya
Get the details | Most sanctions against Libya were lifted in general licenses signed in February, April, and August, 2004. By Executive Order of the President dated September 20, 2004, all prior Executive Orders relative to national emergencies with respect to policies and actions of the Government of Libya were revoked.
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Narcotics - Significant Narcotics Traffickers (Principals of Cali Drug Cartel)
Get the details | Blocked. All property and interests in property owned or controlled by the four Principal Individuals named, as well as others designated by the Secretary of the Treasury, et al. are BLOCKED. Those designees are known as SDNTs on OFAC's listing, to differentiate them from the Specially Designated Narcotics Traffickers under the Kingpin Act, and U.S. persons are prohibited from dealing with them. |
See the specific language in Executive Order 12978 of October 21, 1995 for a description of who is covered.
Penalties for corporate violations up to $500,000; $250,000 and/or up to 20 years in jail for individuals. Civil penalties of up to $50,000 per violation administratively imposed. |
Narcotics - Significant Foreign Narcotics Traffickers (Foreign Narcotics Kingpin Designation Act)
Get the details | Blocked. All property and interests in property owned or controlled by the four Principal Individuals named, as well as others designated by the Secretary of the Treasury, et al. are BLOCKED. | Those designees are known as SDNTKs on OFAC's listing, to differentiate them from the Specially Designated Narcotics Traffickers named under Executive Order 12978 (see above), and U.S. persons are prohibited from dealing with them.
Penalties for corporate violations up to $10 million; $5 million and/or up to 30 years in jail for individuals. Civil penalties of up to $1 million per violation administratively imposed. |
Nonproliferation (Weapons)
Get the details | Prohibited activity. Any transaction by a U.S. person to finance or otherwise participate in the importation into the U.S. of goods, technology, or services produced or provided by foreign persons found by the Secretary of State to have engaged in activities related to the proliferation of nuclear, biological, or chemical weapons is prohibited. | The sanctions affect any U.S. person financing or otherwise participating in the importation into the U.S. of goods, technology, or services produced or provided by foreign persons found by the Secretary of State to have engaged in activities related to the proliferation of nuclear, biological, or chemical weapons. |
North Korea
Get the details | Blocked. Accounts, assets and financial transactions blocked as of June 16, 2000 remain BLOCKED. North Korean goods may not be imported into the U.S. either directly or indirectly through third countries without prior notification of and approval by OFAC.
OFAC Approval Needed. U.S. depository institutions handling letters of credit or documentary collections involving imports from North Korea must obtain a copy of the OFAC approval letter prior to proceeding with these types of transactions.
Prohibited activity. Transfers from North Korea that constitute donations to U.S. persons or pose a risk of furthering terrorist acts in the U.S. are prohibited.
U.S. persons (including financial institutions) are prohibited, effective 5/8/2006, from owning, leasing, operating, or insuring any vessel flagged by North Korea. Foreign subsidiaries of U.S. corporations are not affected by this prohibition.
| Account, asset and financial transactions after June 16, 2000 authorized by OFAC are permitted.
On June 19, 2000 the ban on exports to North Korea was ended provided the exports are licensed or authorized by the Department of Commerce.
Penalties: Up to 10 years in prison, $1 million in corporate fines, and $250,000 in individual fines. Civil penalties of up to $65,000 per violation.
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Sudan
Get the details | Blocked. All property and interests in property of the Government of Sudan that are in the United States, that come within the United States, or that are or come within the possession or control of U.S. persons, including their overseas branches
Prohibited activity. No U.S. bank may finance or arrange offshore financing for, third-country trade transactions where Sudan is known to be the ultimate destination of, or the Government of Sudan is the purchaser of, the goods.
Prohibited Activity. Prohibits U.S. persons from engaging in any transactions involving such property or interests in property. It also prohibits all transactions by U.S. persons relating to Sudan’s petroleum or petrochemical industries, including, but not limited to, oil field services and oil or gas pipelines.
Note: In an Executive Order effective 4/27/06, President Bush directed that assets of certain persons named as threatening the peace process in Darfur, The Sudan, be blocked.
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Penalties: Up to 20 years in prison, $500,000 in corporate fines, and $250,000 in individual fines. Civil penalties of up to $50,000 per violation.
Donations of articles intended to relieve human suffering are permitted.
OFAC may issue registration numbers to non-governmental organizations (NGOs) which authorize the conducting of humanitarian or religious activities that would otherwise be banned.
Effective October 13, 2006, the Sudanese Sanctions no longer prohibit trade and related transactions or humanitarian assistance in the areas of Sudan specified in the Darfur Peace and Accountability Act ("DPAA"), including Southern Sudan, Southern Kordofan/Nuba Mountains State, Blue Nile State, Abyei, Darfur, and marginalized areas in and around Khartoum, provided that the Government of Sudan does not have any property interest in the transaction. In addition, the new Order preserves a full trade ban on the areas of Sudan not specified in the DPAA. Read interpretive guidance on Executive Order 13412, which created those geographic exemptions.
Effective June 13, 2005, OFAC issued a general license authorizing individuals ordinarily resident in Sudan to operate accounts in U.S. financial institutions under certain circumstances. Such persons may not be included within the term "Government of Sudan." Transactions must be of a personal nature.
Also effective June 13, 2004, U.S. depository institutions, U.S. registered brokers and dealers in securities, and U.S. registered money transmitters to process transfers of funds that are noncommercial, personal remittances to or from Sudan or for or on behalf of individuals ordinarily resident in Sudan.
Read the details of the June 13, 2005, action.
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Syria
Get the details. | Exports to Syria are limited. With limited exceptions, property and interests in property BLOCKED of persons designated by State and Treasury Departments as
- contributing to Syria's provision of safe haven to various terrorist organizations;
- involved in Syria's military presence in Lebanon;
- involved in Syria's pursuit of WMD;
- involved in steps taken by Syria to undermine U.S. and international efforts toward stabilization and reconstruction of Iraq;
- owned or controlled by or acting on behalf of any person whose property or interests in property are blocked by the order; or
- involved in certain terrorist acts in Lebanon
The BLOCK order covers contributions on behalf of persons whose property is blocked.
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In a new Executive Order effective April 26, 2006, President Bush ordered the blocking of assets of persons to be identified by the Secretary of the Treasury as involved in certain terrorist acts in Lebanon.
On August 1, 2007, President Bush issued Executive Order 13441, blocking property of persons undermining the sovereignty of Lebanon or its democratic processes and institutions. Included are requirements blocking property of persons supporting the reassertion of Syrian control or contributing to Syrian interference in Lebanon.
Penalties: Up to 20 years in prison, $500,000 in corporate fines, and $250,000 in individual fines. Civil penalties of up to $50,000 per violation.
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Terrorism
Get the details | Blocked. All property subject to U.S. jurisdiction in which there is any interest of Middle East terrorist organizations or those persons designated as Specially Designated Terrorists (SDTs) is BLOCKED.
Prohibited activity. Any transaction or dealing by a U.S. person or within the U.S. in property or interests in property of SDTs, including the making or receiving of any contribution of funds, goods, or services to or for the benefit of such persons is prohibited.
Effective May 10, 2006, U.S. persons are prohibited from engaging in transactions with the Palestinian Authority, unless licensed or otherwise authorized. See the Special Note on License No. 7, at right.
As of April 12, 2006, banks may reject transactions with members of the Palestinian Legislative Council who were elected on the party slate of Hamas or any other terrorist organization, unless the individuals are named on OFAC's list of SDNs and Blocked Persons (in which case, the assets must be BLOCKED). See the Special Note on License No. 7, at right. | A list of Foreign Terrorist Organizations (FTOs) and SDTs designated by the Secretary of State is provided.
OFAC must be notified within ten days of the BLOCKING of any account or transaction.
There are several types of transactions with the Palestinian Authority (P.A.) that are specifically licensed, but no transaction can result in a debit to an account of the P.A. in a U.S. bank or a blocked account.
OFAC announced General License No. 7 on 6/20/07, indicating that U.S. persons are authorized to engage in transactions otherwise prohibited by 31 CFR parts 594, 595, and 597 with the Palestinian Authority, defined for the purposes of the License as the PA government of Prime Minister Salam Fayyad and President Mahmoud Abbas, including branches, ministries, offices, and agencies. On 6/28/07, OFAC updated the guidelines on transactions with the Palestinian Authority on its website to help clarify the scope of General License No. 7. You should direct to OFAC any questions about the effect of this License on dealings with any specific party related to the Palestinian Authority.
Penalties: 20 years' imprisonment. Administrative fines up to $50,000 per violation.
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UNITA (Angola)
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The national emergency in respect to UNITA (Angola) has been terminated. The termination does not affect any action taken or proceeding based on any act committed prior to May 6, 2003. |
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Yugoslavia (Serbia and Montenegro) (sometimes known as FRYM, the Federal Republic of Yugoslavia (Serbia and Montenegro))
| The nation emergency in to Yugoslavia (Serbia and Montenegro) has been terminated. All property blocked prior to May 29, 2003 remains blocked. | The termination does not affect any action taken or proceeding based on any act committed prior to May 29, 2003. |
Zimbabwe - Persons that undermine democratic process or institutions in Zimbabwe
Get the details | BLOCKING. All property and assets of designated persons are BLOCKED and may not be transferred, paid, exported, withdrawn, or otherwise dealt in.
Prohibited activity. The making or receiving by a U.S. person of any contribution or provision of funds, goods, or services to or for the benefit of a designated person is prohibited.
| All persons or entities that would be affected by this sanctions program would be listed on the SDN list.
In addition, any transaction by a U.S. person that evades or avoids or has the purpose of or attempts to violate these prohibitions and any conspiracy to violate the prohibitions is prohibited.
Penalties: Up to greater of $500,000 or twice the pecuniary gain for organizations; greater of $250,000 or twice the pecuniary gain and/or up to 20 years in prison for individuals. Civil penalties up to $50,000 per violation.
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First published on BankersOnline.com 11/7/02
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