Trade Embargoes and Sanctions

U.S. embargoes and economic/trade sanctions are administered by the U.S. Department of Treasury's Office of Foreign Assets Control (OFAC), and are aimed at prohibiting almost any form of business transactions with the governments, companies, and persons that are citizens of embargoed countries or countries subject to U.S. trade sanctions, as well as prohibited entities.

Comprehensive controls apply to countries subject to general embargoes (currently, Cuba and Iran). Accordingly, nearly all items require an OFAC license to be shipped to Cuba or Iran and are subject to a general policy of denial. Also, the transfer of items of value to embargoed nations are prohibited. 

OFAC administers a number of U.S. economic sanctions that target geographic regions and governments and programs related to foreign narcotics traffickers, foreign terrorists, WMD proliferators, etc. Moreover, OFAC publishes a list of individuals and companies owned or controlled by, or acting on behalf of, targeted countries. OFAC also lists individuals, groups, and entities under programs that are not country-specific. Collectively, such individuals and companies are called, "Specially Designated Nationals" (SDNs). Their assets are blocked and U.S. persons are generally prohibited from dealing with them.

Global Trade Expertise can assist clients with determining whether OFAC sanctions apply to specific transactions and can develop compliance processes and procedures to avoid OFAC violations.