OFAC’s regulations are broader than the specific laws dealing with terrorists and persons who support them. All individuals and entities that fall under U.S. jurisdiction should use OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List). This list includes specially designated global terrorists and narcotics traffickers, among other designated persons, and is available on OFAC’s website. In addition, OFAC maintains other sanctions lists that may have different prohibitions associated with each that apply to U.S. persons or transactions otherwise subject to U.S. jurisdiction. It is important to note that some OFAC sanctions block categories of persons even if those persons do not appear on the SDN List. For example, this is the case for any person that meets the definition of the “Government of Venezuela” in Executive Order 13884 of August 5, 2019 (“Blocking Property of the Government of Venezuela”). It is also important to note that OFAC’s Cuba sanctions prohibit most transactions with Cuban nationals, wherever located. U.S. persons are expected to exercise due diligence in determining whether any such persons are involved in a proposed transaction.
August 11, 2020