Trade, Export Controls & Sanctions
New OFAC designations in 2025 alone
Maximum civil penalty per violation (IEEPA, inflation-adjusted)
Ownership threshold triggering blocked status under the 50 Percent Rule
Regulation Overview
https://ofac.treasury.gov/
OFAC administers and enforces U.S. economic and trade sanctions programs targeting foreign countries, regimes, terrorists, narcotics traffickers, weapons proliferators, and other threats to U.S. national security. For supply chain and compliance teams, OFAC sanctions compliance means screening every counterparty—suppliers, customers, freight forwarders, financial intermediaries—against multiple sanctions lists before and during every transaction. OFAC maintains the Specially Designated Nationals and Blocked Persons List (SDN List), the Sectoral Sanctions Identifications List (SSI List), the Non-SDN Menu-Based Sanctions List, the CAPTA List, and the Non-SDN Communist Chinese Military Companies List. The SDN List alone contains tens of thousands of entries and is updated multiple times per week. OFAC added over 1,300 designations in 2025. OFAC sanctions compliance requires real-time screening infrastructure, beneficial ownership analysis under the 50 Percent Rule, and continuous monitoring as lists change. A single unscreened transaction with a sanctioned party creates strict liability exposure—regardless of intent.
Key Components / Sub-Frameworks
All U.S. citizens and permanent residents, worldwide\nAll entities organized under U.S. law, including foreign branches\nNon-U.S. persons engaging in transactions with a U.S. nexus\nNon-U.S. entities owned or controlled by U.S. persons\nForeign financial institutions processing U.S. dollar transactions\nAny person causing a U.S. person to violate sanctions (facilitation)
Key Thresholds
OFAC updates the SDN List multiple times per week. In 2025, over 1,300 new designations were added—spanning cartels, scam networks, shadow fleet vessels, and sanctioned government officials. Your screening ran Monday. A new designation published Tuesday. Your payment processed Wednesday. You are now in violation.
An SDN owns 30% of Company A. A second SDN owns 25% of Company A. Neither ownership exceeds 50%, but aggregate SDN ownership is 55%—making Company A blocked property. Without beneficial ownership analysis across your entire supplier base, you cannot identify these indirect exposures.
OFAC enforces civil penalties on a strict liability basis. Your compliance team screened the supplier name but missed a subsidiary three tiers deep that is 60% owned by an SDN. The payment clears. OFAC identifies the violation. Intent is irrelevant. Penalty exposure is immediate—up to $377,700 per transaction or twice the value.
OFAC administers over 30 sanctions programs—each with different prohibitions, general licenses, and exceptions. Russia-related sanctions differ from Iran sanctions. Cuba comprehensive sanctions differ from Venezuela sectoral restrictions. Your compliance team needs program-specific expertise for every transaction, across every supplier relationship, continuously.
Certivo In Action
Certivo in Action — OFAC Sanctions Workflow
From Manual List Checks to AI-Native Compliance Automation
CORA screens every counterparty, resolves matches, and calculates beneficial ownership exposure automatically. Your team focuses on true matches and risk decisions—not manual spreadsheet lookups.
Screening Documentation Acceleration
Generate complete, audit-ready OFAC compliance reports with full match resolution and ownership analysis in hours—not the weeks of manual compilation.
Proactive OFAC Sanctions Monitoring
When OFAC publishes new designations, Certivo rescreens your entire counterparty base instantly. Know your exposure before the next transaction processes—not after enforcement action.
Key Statistics
Frequently Asked Questions
Who must comply with OFAC sanctions regulations?
All U.S. persons—citizens, permanent residents, entities organized under U.S. law, and their foreign branches—must comply with OFAC sanctions. Non-U.S. persons face exposure when transactions involve U.S. dollar clearing, U.S.-origin goods, or any U.S. nexus. Secondary sanctions in certain programs (Iran, Russia) extend reach to non-U.S. entities. Certivo screens your entire counterparty base and maps jurisdictional exposure across all active OFAC programs.
What are the penalties for OFAC sanctions violations?
Civil penalties under IEEPA reach the greater of $377,700 per violation (inflation-adjusted) or twice the transaction value. Criminal penalties for willful violations include fines up to $1 million and imprisonment up to 20 years. OFAC's 2025 enforcement included a $216 million settlement against a single investment adviser. Strict liability applies—meaning even accidental, unintentional violations carry full civil penalty exposure.
How does Certivo handle the OFAC 50 Percent Rule?
Certivo collects beneficial ownership declarations from suppliers and cross-references them against OFAC designations. CORA calculates aggregate SDN ownership across multiple blocked persons to identify entities that are blocked by operation of the 50 Percent Rule—even when no single SDN holds a majority stake. This goes beyond name matching to capture the ownership-based exposure that OFAC expects companies to identify.
How does Certivo keep screening current as OFAC lists change?
Certivo maintains real-time sync with all OFAC sanctions lists—SDN, SSI, consolidated non-SDN lists, and program-specific designations. When OFAC publishes new designations or removes entries, Certivo automatically rescreens your entire counterparty base and alerts you to new matches. This continuous monitoring replaces the periodic batch-screening approach that creates gap exposure between runs.
How does OFAC screening relate to EAR, ITAR, and other export control compliance?
OFAC sanctions, BIS Entity List (EAR), ITAR restrictions, and EU sanctions lists all target overlapping but distinct sets of restricted parties. A single supplier may appear on multiple lists under different programs. Certivo screens against OFAC, BIS, and EU restricted party lists simultaneously from one supplier submission—providing multi-jurisdiction screening that eliminates duplicate screening workflows across trade compliance programs.