Do OFAC Sanctions Apply to Dual Nationals and US Green Card Holders?
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Do sanctions against a country apply to its dual nationals or US residents?

Yes. OFAC’s “U.S. person” definition, applied consistently across every sanctions program under the International Emergency Economic Powers Act (50 U.S.C. §§ 1701–1706), covers U.S. citizens and lawful permanent residents (green card holders) wherever they are physically located, including dual nationals, plus anyone physically present in the United States regardless of nationality. A U.S.-Iranian dual national living in Tehran remains bound by the Iranian Transactions and Sanctions Regulations (31 CFR Part 560); a U.S. citizen residing in Moscow remains bound by the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR Part 587). The definition also reaches entities organized under U.S. law, including their foreign branches, and — for Cuba and Iran specifically — foreign entities that a U.S. person owns or controls by 50% or more. Non-U.S. persons without any U.S. nexus generally fall outside primary sanctions but can still face secondary-sanctions exposure.

Cliodhna Joyce-Daly
Strategic Legal Consultant and Jurisdictional Expert
Cliodhna Daly is an Irish qualified solicitor whose significant international legal experience and practice in civil law make her a valuable expert for clients dealing with OFAC blocked funds issues. Her commitment to social justice, underscored by a Master of Laws degree, guarantees a meticulous and ethical approach to resolving complex international financial and legal problems.

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