U.S. sanctions laws restrict the flow of money, goods, information, or services between U.S. and certain non-U.S. persons—including U.S. financial institutions—and restricted countries, parties, and activities.
Our attorneys are experienced with helping multinational companies and financial institutions comply with U.S. sanctions. We can assist with any inquiry you may have.
For example, Wardlaw Trade Law can help you:
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We can also work with partners to audit your transactions, assess your restricted party screening software’s settings, and respond to a government subpoena or investigation.
U.S. sanctions are primarily administered by the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”).
While U.S. sanctions generally focus on restricting the actions of U.S. persons, they may also restrict the activities of non-U.S. persons by:
U.S. sanctions primarily take three forms:
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Monitoring these restrictions can be more difficult than it first appears, as updates must be read in the context of cumulative restrictions and authorizations, but they are not usually published that way.
Moreover, OFAC maintains public lists of restricted parties, such as its list of Specially Designated Nationals and Blocked Persons (the “SDN List”). Persons who are subject to OFAC’s jurisdiction are expected to screen their counterparties against these lists. However, sanctions due diligence cannot be limited to screening against the public lists alone. Unfortunately, many parties who are not listed are nonetheless “constructively” captured by the lists through OFAC’s “50% Rule” (capturing parties 50% or more owned, directly or indirectly, by one or more listed parties, when their interests are aggregated) or are subject to similar restrictions by regulation or executive order (like many blocked governments and their agencies and state-owned enterprises).