Sanctions measures beyond blocking
Besides blocking property, OFAC's list records further measures on some designations — secondary sanctions risk, directives, menu-based measures. Each one is listed here with how many entries carry it and OFAC's own wording.
What these are
OFAC publishes these as notes on a designation's entry. Each label below is our shorthand for one kind of note; the quoted text beside it is OFAC's own wording, as one listed entry records it. This page reproduces what OFAC's list records. It is not legal advice on what applies to a particular transaction.
Secondary sanctions risk
An entry with a secondary sanctions risk note is one for which OFAC's list records that foreign persons — including foreign financial institutions — that engage in certain transactions with or for the listed party may themselves be sanctioned, under the authority the note cites. The note names the authority; which transactions it reaches is set out in that authority and in OFAC's guidance on it.
Directives and other measures
A directive note records that the party is subject to a numbered OFAC directive, often with the directive's effective date; the directive itself sets out the dealings it prohibits. An investment-prohibition note records a prohibition on investment in the listed party's securities under the authority it cites (for example the Chinese Military-Industrial Complex program), with the listing, effective and divestment dates OFAC records for it. Menu-based measures record sanctions selected for the party under an authority that provides a menu of them. Other information reproduces the remaining notes OFAC files on an entry.
Secondary sanctions risk
| Measure | As OFAC's list words it (example) | Active entries |
|---|---|---|
| Russia: EO 14024 §11 (foreign financial institutions) | Secondary sanctions risk: See Section 11 of Executive Order 14024. | 6,431 |
| Terrorism: EO 13224 §1(b), as amended by EO 13886 | Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886 | 3,347 |
| Iran-related: "Subject to Secondary Sanctions" | Additional Sanctions Information - Subject to Secondary Sanctions | 2,598 |
| Ukraine/Russia: 31 CFR 589.201 / 589.209 | Secondary sanctions risk: Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201 and/or 589.209 · Secondary sanctions risk: Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201 | 1,453 |
| North Korea: 31 CFR 510.201 / 510.210 | Secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210 | 675 |
| Hizballah Financial Sanctions Regulations | Additional Sanctions Information - Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations | 280 |
| Hong Kong Autonomy Act of 2020 | Secondary sanctions risk: pursuant to the Hong Kong Autonomy Act of 2020 - Public Law 116-149 | 39 |
Transactions prohibited for persons owned or controlled by U.S. financial institutions
| Measure | As OFAC's list words it (example) | Active entries |
|---|---|---|
| North Korea: 31 CFR 510.214 (foreign entities owned or controlled by U.S. financial institutions) | Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214 | 672 |
Directives
| Measure | As OFAC's list words it (example) | Active entries |
|---|---|---|
| Ukraine-/Russia-related: EO 13662 Directive 1 | Executive Order 13662 Directive Determination - Subject to Directive 1 | 176 |
| Ukraine-/Russia-related: EO 13662 Directive 4 | Executive Order 13662 Directive Determination - Subject to Directive 4 | 111 |
| Ukraine-/Russia-related: EO 13662 Directive 2 | Executive Order 13662 Directive Determination - Subject to Directive 2 | 67 |
| Ukraine-/Russia-related: EO 13662 Directive 3 | Executive Order 13662 Directive Determination - Subject to Directive 3 | 55 |
| Directive dates (EO 14024 Directive 2) | Effective Date (EO 14024 Directive 2): · Listing Date (EO 14024 Directive 2): | 39 |
| Russia: EO 14024 Directive 3 | Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited. | 16 |
| Russia: EO 14024 Directive 1A | Executive Order 14024 Directive Information Subject to Directive 1a - As of the effective date, participation in the secondary market for ruble or non-ruble denominated bonds issued on or after the effective date by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation is prohibited. | 3 |
| Russia: EO 14024 Directive 4 | Executive Order 14024 Directive Information Subject to Directive 4 - any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities is prohibited. | 3 |
| Burma: EO 14014 Directive 1 | Executive Order 14014 Directive Information: Subject to Directive 1 - As of the effective date, the provision, exportation, or reexportation, directly or indirectly, of financial services to or for the benefit of Myanma Oil and Gas Enterprise (MOGE) or its property or interests in property is prohibited. | 1 |
Investment prohibition
| Measure | As OFAC's list words it (example) | Active entries |
|---|---|---|
| Chinese Military-Industrial Complex: securities investment prohibition (EO 13959, as amended by EO 14032) | Effective Date (CMIC) · Listing Date (CMIC) · Purchase/Sales For Divestment Date (CMIC) | 68 |
Menu-based measures
| Measure | As OFAC's list words it (example) | Active entries |
|---|---|---|
| BLOCKING PROPERTY AND INTERESTS IN PROPERTY. Sec. 5(a)(iv) | Executive Order 13846 information: BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON. Sec. 5(a)(v) · Executive Order 13846 information: BANKING TRANSACTIONS. Sec. 5(a)(iii) · Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY. Sec. 5(a)(iv) | 229 |
| BLOCKING OF PROPERTY. Sec.6(b)(1)(A),(B),(C) - All property and interests in property of this individual are blocked, and all transactions with this individual are prohibited, except for the importation of goods. | HKAA Section 6 Information: BLOCKING OF PROPERTY. Sec.6(b)(1)(A),(B),(C) - All property and interests in property of this individual are blocked, and all transactions with this individual are prohibited, except for the importation of goods. | 39 |
| BANKING TRANSACTIONS. Sec 235(a)(8) | CAATSA Section 235 Information: BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON. Sec 235(a)(10) · CAATSA Section 235 Information: BANKING TRANSACTIONS. Sec 235(a)(8) · CAATSA Section 235 Information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY. Sec 235(a)(9) | 8 |
| IFCA determination: Involved in the Shipping Sector | IFCA Determination - Involved in the Shipping Sector | 5 |
| BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON. Sec.2(b)(1)(J) - Any United States person is prohibited from investing in or purchasing significant amounts of equity or debt instruments of this entity. | PAIPA Section 2 Information: BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON. Sec.2(b)(1)(J) - Any United States person is prohibited from investing in or purchasing significant amounts of equity or debt instruments of this entity. · PAIPA Section 2 Information: BANKING TRANSACTIONS. Sec.2(b)(1)(I) - Any transfers of credit or payments between financial institutions or by, through, or to any financial institution, to the extent that such transfers or payments are subject to the jurisdiction of the United States and involve any interest of this entity, are prohibited. · PAIPA Section 2 Information: BLOCKING OF PROPERTY (entity). Sec.2(b)(1)(A) - All property and interests in property of this entity are blocked, and all transactions with this entity are prohibited, except for the importation of goods. | 3 |
| Prohibition on any transactions in foreign exchange that are subject to the jurisdiction of the United States and in which this target has any interest | Executive Order 14059 information: Prohibition on any transactions in foreign exchange that are subject to the jurisdiction of the United States and in which this target has any interest · Executive Order 14059 information: Prohibition on any United States financial institution from making loans or providing credit to this target · Executive Order 14059 information: Prohibition on any United States person from investing in or purchasing significant amounts of equity or debt instruments of this target | 1 |
| Property and Interests in Property Blocked, Except Importation of Goods | PEESA Information: Property and Interests in Property Blocked, Except Importation of Goods | 1 |
Counts are of active entries whose OFAC entry carries the note. One entry can carry several measures, so the counts do not add up to a number of designations. Each measure's page lists the entries and quotes OFAC's wording as they record it.
Looking at one designation? Its entry page lists every measure OFAC's list records for it, under “Sanctions measures beyond blocking”.