By · · last updated 2026-08-06
Secondary sanctions reach beyond US jurisdiction: foreign persons can be sanctioned for significant transactions with designated parties. What agents need to know.
Primary sanctions prohibit US persons from transacting with designated parties. Secondary sanctions extend the reach: foreign persons can face designation for significant transactions with sanctioned parties - even with no US nexus.
Primary: US persons, US-origin goods, USD transactions. Secondary: non-US persons who facilitate or materially support sanctioned activity - banking, trading, or clearing for designated parties.
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An agent operating outside the US is not automatically outside OFAC's reach. A payment agent that clears or facilitates for a sanctioned party can create secondary-sanctions exposure for its operator, regardless of jurisdiction.
Screen counterparties against the SDN list and the applicable international lists; document the controls; fail closed. The embargoed-jurisdiction explainer and the sanctions lists index cover the surfaces.
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