OFAC

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The Department of Treasury’s Office of Foreign Asset Controls (“OFAC”) administers financial and economic sanctions against specific countries in response to some form of wrongdoing. OFAC sanctions are targeted broadly against 1) foreign governments and political entities, 2) individuals and groups ranging from terrorists and drug cartels to banks and other financial institutes that support those types of activities, 3) entities such as charities linked to terrorism, and 4) certain activities such as those that would lead to nuclear proliferation or otherwise violation U.S. policy interests.

Well-known sanctions programs include complete embargoes or more limited restrictions on trade with Cuba, Iran, Syria, and North Korea. Other programs include more targeted sanctions on the property of specified people from countries including Russia, Venezuela, Belarus, the Congo, and elsewhere. Collectively, such individuals and companies are called "Specially Designated Nationals" or "SDNs." Their assets are blocked, and U.S. persons are prohibited from dealing with them. Both the sanctions programs and the SDN List are constantly changing and companies that do business internationally, particularly in political ‘hot spots’ are well advised to constantly monitor OFAC developments.

OFAC’s sanctions apply to all U.S. citizens and permanent residents wherever they are located. It also applies to any person who is physically in the United States regardless of his citizenship. U.S. companies and all branches of U.S. organizations throughout the world remain subject to OFAC. Likewise, U.S. branches or offices (physically located in the U.S.) of foreign corporations are subject to OFAC.

Attorneys at Barnes, Richardson are well versed in sanction law and can provide guidance on how to tailor transactions, including financial transactions, so they remain complaint with the OFAC law. Barnes, Richardson attorneys assist companies in all areas of OFAC compliance, including building and auditing robust OFAC compliance programs, preparing and submitting voluntary disclosures to OFAC, and engaging in other representations before that agency.

Nov. 5, 2025: White House Caps China IEEPA Fentanyl and Reciprocal Tariffs at 10%
Nov. 4, 2025: U.S. and China Strike Trade Deal — Export Controls Front and Center
Oct. 30, 2025: U.S.-Korea Trade Deal Details Released
Oct. 28, 2025: Japan in Critical Minerals Agreement with U.S.
Oct. 27, 2025: Trump Terminates Talks on Trade with Canada
Oct. 27, 2025: USTR Confirms Trade Frameworks with Cambodia, Malaysia, Thailand, Vietnam (so far)
Oct. 21, 2025: USTR Considers 301 Tariffs and Suspended CAFTA-DR Benefits for Nicaragua
Oct. 17, 2025: Trump Imposes Heavy Truck and Bus 232 Starting November 1
Oct. 16, 2025: Cassidy Pitches Carbon Tax as IEEPA Replacement
Oct. 9, 2025: Changes to Steel and Aluminum Duties are in the Wind
Oct. 7, 2025: Trump Announces New 25% Tariff on All Medium and Heavy-Duty Trucks
Oct. 6, 2025: BIS Expends Entity List with Entity 50 Percent Rule
Sep. 30, 2025: 232 Duties on Wood Products to be Implemented October 14
Sep. 25, 2025: U.S. Updates Tariff to Reflect EU Framework Agreement
Sep. 25, 2025: Up is Down and Bread is Pasta
Sep. 25, 2025: Commerce Launches 232 Investigations into Medical Supplies, Robotics, and Industrial Machinery
Sep. 24, 2025: CIT Vacates Forced Labor Determination as "Arbitrary and Capricious"
Sep. 24, 2025: CIT Affirms Classification of Fish Oil
Sep. 24, 2025: Withhold Release Order Issued for Giant Bicycles, Parts, and Accessories
Sep. 22, 2025: CBP Determines New Origin for Brake Hoses
Sep. 16, 2025: Steel and Aluminum Derivatives Open for *More* Additions (Somehow)
Sep. 16, 2025: USTR Opens Comments for 2026 USMCA Review
Sep. 16, 2025: Commerce Issues Interim Auto Parts 232 Inclusion Process Information
Sep. 15, 2025: Implementing Some Tariff-Related Elements of the U.S.-Japan Agreement
Sep. 12, 2025: U.S. Tariff Focus in the Limelight of Mounting Russia Sanctions Debate
Sep. 8, 2025: Another Friday Surprise: Reciprocal Tariff Coverage Modified
Sep. 5, 2025: U.S. Seeks Expedited Writ of Certiorari from SCOTUS on IEEPA Tariffs Case
Sep. 5, 2025: 500% Tariffs & Other Sanctions Looming on Russia And Its Trading Partners
Sep. 5, 2025: U.S.–Japan Trade Deal Clarified to 15% Inclusive, Retroactive Tariff
Sep. 5, 2025: Mexico Considering Increasing Non-FTA Tariffs
Sep. 2, 2025: BIS Ending Validated End User (VEU) Program
Aug. 29, 2025: Court of Appeals for the Federal Circuit Rules Against IEEPA Tariffs
Aug. 21, 2025: US and EU confirm Trade Framework in Joint Statement
Aug. 19, 2025: High-Priority Sectors Added to UFLPA Enforcement
Aug. 18, 2025: CBP Touts (Some) Dumping Evasion Wins
Aug. 15, 2025: New AD/CVD Petitions on High Purity Dissolving Pulp from Brazil and Norway
Aug. 15, 2025: Commerce Adds 407 (!) HTS Codes to 232 Derivative Annexes Starting Monday
Aug. 14, 2025: U.S. Eyes Content Percentage for "Transshipment" Enforcement
Aug. 11, 2025: Trump Extends China Tariffs by 90 Days
Aug. 11, 2025: Creatively Ambiguous Japan Deal has Unstacked 15% Baseline
Aug. 8, 2025: Indications of Steel and Aluminum Quotas for EU in Trade Deal
Aug. 6, 2025: Additional 25% Tariffs on Indian Imports Announced
Aug. 1, 2025: New Round of Global Tariffs: A Round Up
Jul. 31, 2025: Copper 232 Coverage Issued Through Customs
Jul. 30, 2025: Gird Your Wires: Copper Tariffs Coming August 1st
Jul. 30, 2025: Brazil Gets Its Own IEEPA Tariffs
Jul. 30, 2025: De Minimis Window to Close August 29

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Jan. 22, 2025: Webinar: What We Know After the Inauguration
Sep. 9, 2024: McPherson to Co-Moderate Export Enforcement Discussion
Jun. 2, 2023: BRC and Attorneys Ranked in 2023 Chambers Guide
May 12, 2015: Partner Helena Sullivan Speaks at New York City Bar Association on OFAC Compliance
April 8, 2013: Barnes/Richardson Partner Quoted in Ria Novosti Article