US sanctions listsThe most important facts about US sanctions at a glance
What are sanctions?
Sanctions are measures imposed by the United Nations or countries such as the USA on individuals, companies, organizations or entire regions and nations. The background is often violations of human rights or threats to national security. The sanctions are always published as a sanctions list. In most cases, a whole series of lists must be compared with the respective business contacts and employee lists.
What types of sanctions does the USA impose?
The USA imposes financial sanctions as well as economic and trade sanctions (embargoes). A special feature of US sanctions is the distinction between primary and secondary sanctions:
- Primary sanctions: relate to US persons, US goods and US transactions
- Secondary sanctions: relate to persons without a US connection but with a business relationship with the targets of a primary sanction
Examples: Who or what is currently listed in US sanctions?
The persons, companies and countries listed under US sanctions currently (as of May 2025) include, for example, certain
- Russian shadow fleets
- various Iranian companies
- Chinese quantum computing research facilities
- Mexican drug cartels
- and many more.
Important: The groups and organizations listed above are just examples. Only the complete, current US sanctions lists provide a precise overview of the current sanctions targets!
What goals are the USA pursuing with its sanctions?
When imposing sanctions, the focus is usually on foreign policy and security policy interests. For example, the aim is to prevent human rights violations, the proliferation of weapons of mass destruction, terrorism and corruption.
Which US authority is responsible for sanctions in the USA?
In the USA, sanctions lists are issued by various public authorities, including the US Department of the Treasury, the US Department of Commerce and the US Department of State. These include, in particular, the following US authorities:
- Office of Foreign Assets Control (OFAC)
- Bureau of Industry and Security (BIS)
- Directorate of Defense Trade Controls (DDTC)
Are the US sanctions lists relevant for EU companies?
When EU companies are affected by US sanctions
Companies based in the EU must keep an eye on the various EU sanctions lists in their business relationships and transactions. A regular, thorough sanctions list check is the only way to avoid potential compliance violations. However, the US sanctions lists are also relevant for them. This applies in two cases:
1) The company has connections to US business contacts and / or US employees or to US goods and / or transactions in US currency.
2) The company does business with or conducts transactions with entities affected by primary US sanctions. Then the secondary US sanctions apply.
Important to note for case 2)
In 1996, the European Union issued the EU Blockade Regulation EC No. 2271/96, which protects entrepreneurs in the European Customs Union from the legal effect of extraterritorial sanctions (e.g. the US sanctions from case 2) on EU soil – but not from the US sanctions themselves. The US sanctions lists should therefore also be kept in mind – especially as soon as there is direct contact with US goods, payments, persons and organizations. This is because the USA generally punishes violations of its sanctions lists with high fines and further sanctions.
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Which US sanctions lists are there?
A brief overview of current US sanctions lists and their impact (as of May 2025):
Specially Designated Nationals and Blocked Persons List (SDN List)
The OFAC Specially Designated Nationals and Blocked Persons List (SDN List) is one of the most important US sanctions lists and contains key financial sanctions.
- Publisher: Office of Foreign Assets Control (OFAC), US Department of Treasury
- Sanctioned: Companies and individuals, organizations as well as ships and aircraft
- Focus:Terrorism, cybercrime, money laundering
- Measures: Freezing of assets, prohibition of transactions and investments
- Link: SDN List as download or OFAC Sanctions List Search Tool
OFAC Consolidated Sanctions List (CSL)
With the Consolidated Sanctions List (CSL), OFAC provides an overview of all sanctions lists issued by OFAC that do not belong to the SDN List (Non-SDN Lists). These include
- Sectoral Sanctions Identifications List (SSI List)
- Foreign Sanctions Evadors List (FSE List)
- Non-SDN Palestinian Legislative Council List
- Non-SDN Iran Sanctions Act List (NS-ISA List)
- List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List)
- Non-SDN Menu-Based Sanctions List (NS-MBS List)
- Non-SDN Menu-Based Sanctions List (NS-CMIC List)
An overview of the most important facts about the Consolidated OFAC List:
- Publisher: Office of Foreign Assets Control (OFAC), US Department of Treasury
- Sanctioned: varies depending on the sanctions list (e.g. Foreign Sanctions Evaders)
- Focus:specific sanctioned countries or areas
- Measures: Restrictions on the export of certain goods
- Link: Consolidated Non-SDN List as download or OFAC Sanctions List Search Tool
Entity List
- Publisher: Bureau of Industry and Security (BIS), US Department of Commerce
- Sanctioned / subject to export controls: foreign companies and research institutions
- Focus: Military, 5G, AI technologies
- Measures: Licensing requirements for exports
- Link: as PDF-Dokument or Online-Übersicht
Denied Persons List
- Publisher: Bureau of Industry and Security (BIS), US-Handelsministerium
- Sanctioned: People and companies
- Focus: Sanctions for unauthorized transfer of US technologies, among other things
- Measures: Export ban
- Link: DPL as online overview
Unverified List (UVL)
- Publisher: Bureau of Industry and Security (BIS), US Department of Commerce
- Sanctioned: Individuals and companies
- Focus: No end-use verification for exports can be implemented for sanctioned entities
- Measures: No license exceptions for the export of items subject to the Export Administration Regulations (EAR) to sanctioned entities
- Link: UVL as online overview
Debarred Parties List
- Publisher: Directorate of Defense Trade Controls (DDTC), US Department of State
- Sanctioned: Individuals and companies
- Focus: Entities sanctioned for violating US arms trade regulations (arms export controls)
- Measures: No US arms exports
- Link: Online view and download options
