In addition to comprehensive sanctions programs against Cuba, Iran, North Korea, Syria and the Crimea region of Ukraine, the US also maintains targeted sanctions programs.  Targeted sanctions generally prohibit US persons from transacting with an individual or entity that is designated by the State or Treasury Departments pursuant to the individual listing criteria under a specific sanctions regime, such as the Terrorism Sanctions and the Foreign Narcotics Kingpin Sanctions.  Treasury also has the authority to designate entities owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, someone who meets this criteria.

Individuals or entities may be included on a list for one or more reasons, including narcotics trafficking, terrorism, nuclear or other weapons of mass destruction proliferation activities, or human rights violations.  Sanctioned entities may include foreign governments and foreign government entities.

A person designated will be added to OFAC’s SDN List and his or her property and interest in property will be blocked. 

There is a general prohibition on entering into a transaction involving an SDN.  For more on the OFAC sanctions lists and implications of designation, see here.

High-Risk Countries.  The following countries generally are considered to be “high-risk” because they are subjects of an OFAC targeted sanctions program or they contain high numbers of sanctioned individuals:  Afghanistan; the Balkans; Belarus; Burundi; Central African Republic; Colombia; the People’s Republic of China; the Democratic Republic of the Congo; Hong Kong; Iraq; Lebanon; Libya; Mexico; Pakistan; the Palestinian Authority; Panama; Russia; Somalia; South Sudan; Sudan; Ukraine; Venezuela; Yemen; and Zimbabwe.

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