OFAC Sanctioned Countries — Full List & Legal Impact
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The United States Office of Foreign Assets Control (OFAC) administers the most extensive and extraterritorially powerful sanctions regime in the world. OFAC sanctions operate against both entire countries (comprehensive sanctions programs) and against specific individuals, companies, and entities worldwide (targeted designations on the Specially Designated Nationals and Blocked Persons list, or SDN list). Understanding which countries are subject to OFAC sanctions — and what this means in practice — is essential for individuals and businesses with any US connection or reliance on the US financial system.
How OFAC Sanctions Work
OFAC is a division of the US Department of the Treasury. It administers and enforces economic and trade sanctions based on US foreign policy and national security objectives. OFAC acts under executive and legislative authority — primarily executive orders issued by the President, and specific statutes including the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA).
OFAC sanctions operate in two principal ways. First, comprehensive country-based sanctions programs prohibit virtually all transactions between US persons (including US companies and their foreign subsidiaries) and the sanctioned country or its government. Second, the SDN list designates specific individuals and entities — wherever they are located in the world — whose assets are blocked and with whom US persons and many non-US entities are prohibited from dealing.
The extraterritorial reach of OFAC sanctions is exceptional. Even companies and individuals with no US presence can face OFAC penalties if they conduct transactions in US dollars (which pass through the US financial system), use US financial institutions, or engage with US counterparties. This is what makes OFAC designation so severe: it effectively cuts a person or entity off from the global US-dollar financial system.
Comprehensive OFAC Sanctions Programs — Sanctioned Countries
OFAC currently administers comprehensive or near-comprehensive sanctions programs against the following countries and regions:
Cuba
One of the longest-running US sanctions programs, dating to 1962. The Cuban Assets Control Regulations (CACR) prohibit virtually all transactions with Cuba, Cuban nationals, and Cuban-owned entities. US persons require specific OFAC licences for almost any engagement with Cuba, including travel-related transactions.
Iran
Iran is subject to some of the most comprehensive and complex US sanctions in operation. The Iranian Transactions and Sanctions Regulations (ITSR) and the Iran Sanctions Act impose broad prohibitions covering oil and gas, financial services, shipping, insurance, and virtually all commercial activity. Secondary sanctions extend these restrictions to non-US entities dealing with sanctioned Iranian entities, making Iran one of the highest-risk jurisdictions globally.
North Korea
North Korea (DPRK) is subject to comprehensive US sanctions under the North Korea Sanctions Regulations, combined with UN Security Council resolutions imposing multilateral sanctions. The program targets arms, nuclear weapons, ballistic missile programs, and the North Korean financial system.
Syria
The Syrian Sanctions Regulations impose comprehensive restrictions on dealings with the Syrian government and certain Syrian entities. The program was significantly expanded following the Syrian civil war. It includes blocking of government assets and broad restrictions on services related to the energy sector.
Russia and Belarus
Following Russia’s invasion of Ukraine in February 2022, the United States, European Union, and United Kingdom imposed the most extensive sanctions regime against a major economy since the Second World War. US OFAC sanctions target the Russian financial sector (including blocking of major Russian banks), the energy sector, the defense and technology sectors, and numerous individual oligarchs, officials, and connected entities. Belarus is subject to related sanctions targeting the Lukashenko regime and its support for Russia.
Venezuela
Venezuela is subject to a significant US sanctions program targeting the Maduro government, the Venezuelan oil sector (PDVSA), and connected financial networks. The program has been expanded over several years to include blocking of Venezuelan government assets and restrictions on dealings with designated Venezuelan officials and companies.
Myanmar (Burma)
Following the military coup in February 2021, the United States imposed sanctions on Myanmar’s military junta and connected entities, targeting the arms sector, gemstone trade, and certain financial institutions.
The Balkans
Targeted sanctions under the Western Balkans Executive Order target individuals and entities undermining democracy, rule of law, and stability in the Western Balkans region.
The SDN List — Individual and Entity Sanctions
Beyond country-based programs, the SDN list is the primary tool OFAC uses to target specific individuals and entities. As of 2025, the SDN list contains over 13,000 entries from more than 100 countries. Designation on the SDN list has immediate and severe consequences:
All assets of the designated person or entity that are within US jurisdiction (including assets held in US financial institutions) are immediately blocked. US persons are prohibited from any transaction with the SDN-listed person or entity. Non-US banks and financial institutions that process transactions involving SDN-listed parties face massive OFAC penalties — often running to hundreds of millions of dollars — which makes virtually every international bank refuse to deal with SDN-listed parties regardless of their nationality.
OFAC designates individuals based on a range of programs including counter-terrorism (SDGT), counter-narcotics (SDNTK), proliferation of weapons of mass destruction, cyber-related activities, human rights abuses, and country-specific programs. Being designated in any one program results in SDN-list placement with the same consequences regardless of the underlying basis.
Secondary Sanctions — The Global Reach of OFAC
One of the most significant developments in US sanctions law in recent years is the use of secondary sanctions. These provisions target non-US persons and entities that conduct transactions with US-sanctioned parties, even when those transactions have no direct US nexus. Secondary sanctions allow the US to effectively coerce foreign banks, companies, and individuals into compliance with US sanctions policy under threat of being cut off from the US financial system themselves.
Secondary sanctions have been particularly significant in the context of Iran, Russia, and North Korea. European companies, banks, and individuals have faced secondary sanctions risk for dealings with sanctioned Iranian or Russian entities even where no US law technically applies to the transaction in question.
How OFAC Sanctions Affect Individuals — Personal Designation
Individual designation on the OFAC SDN list has consequences that extend far beyond the United States. As a practical matter, no major international bank will maintain accounts or process transactions for an SDN-listed individual. This means the designated person cannot access banking services, make international transfers, pay suppliers, or receive legitimate income through the global banking system.
Travel is also severely restricted. Many countries that host SDN-listed individuals face diplomatic pressure to take action. Visas may be refused by countries that coordinate sanctions policy with the United States, including the EU, UK, Canada, and Australia. In jurisdictions with strong US relations, SDN-listed individuals may face local legal consequences in addition to the US restrictions.
Challenging OFAC Designations — Delisting Petitions
OFAC provides a formal administrative process for challenging SDN designations. A Request for Administrative Reconsideration (a delisting petition) can be filed by designated persons or by third parties whose property is blocked. The petition must demonstrate that the basis for designation is factually incorrect, that circumstances have changed sufficiently to warrant reconsideration, or that the designation is otherwise inconsistent with OFAC’s authorities and applicable law.
Delisting petitions are technically complex and require detailed factual submissions, legal argument, and a thorough understanding of OFAC’s evidentiary standards. Our Cyprus-based OFAC lawyers have experience advising on SDN designation challenges, coordinating with US counsel, and managing the full delisting process from initial review through to OFAC decision.
OFAC stands for the Office of Foreign Assets Control, a division of the US Department of the Treasury. It administers and enforces US economic and trade sanctions against foreign countries, governments, individuals, and entities. OFAC manages country-based comprehensive sanctions programs and the SDN (Specially Designated Nationals) list, which targets specific individuals and entities worldwide whose assets are blocked and with whom US persons are prohibited from dealing.
Countries subject to comprehensive or near-comprehensive OFAC sanctions programs include Cuba, Iran, North Korea, Syria, Russia (for key sectors including finance, energy, and defence), Belarus, Venezuela, and Myanmar. The Russia and Belarus programs have expanded significantly since 2022. OFAC also administers targeted (non-comprehensive) sanctions programs against many other countries and regions including the Western Balkans, Yemen, Somalia, and Zimbabwe.
Yes. OFAC designates individuals and entities from any country in the world. The SDN list contains entries from over 100 countries. Designation affects non-US persons by blocking their US-held assets and prohibiting all US persons from transacting with them. In practice, the consequences extend globally because international banks universally comply with SDN restrictions to avoid OFAC penalties, regardless of the designated person’s nationality.
An OFAC SDN designation can be challenged through a formal administrative reconsideration petition filed with OFAC’s Office of Global Targeting. The petition must present factual evidence and legal argument demonstrating that the basis for designation is incorrect or that circumstances have materially changed. This process is technically demanding and typically requires specialist OFAC lawyers. Our Cyprus-based team advises on SDN challenges and coordinates with US counsel for the submission process.
No. EU sanctions (administered by the European Commission and EU Council), UK sanctions (administered by OFSI — the Office of Financial Sanctions Implementation, part of HM Treasury), and US OFAC sanctions are separate legal regimes with their own lists, procedures, and legal bases. There is significant overlap — particularly for Russia, Iran, and terrorist financing — but designation on one list does not automatically mean designation on others, and the challenge procedures are different for each regime.
