Who is considered a US person under OFAC?

A sanctioned person is an individual or entity that has been formally designated by OFAC as subject to blocking or restrictive measures — most commonly by placement on the Specially Designated Nationals and Blocked Persons (SDN) List, though some programs use other designation mechanisms. Being a “sanctioned person” is a status assigned to a specific party based on their conduct, ownership, or affiliations; it is unrelated to the “U.S. person” classification, which instead determines who is legally obligated to comply with sanctions. A U.S. citizen can be a sanctioned person (if designated) at the same time as being a U.S. person (subject to compliance obligations) — the two categories describe different things and are not mutually exclusive.

Yes. U.S. citizenship provides no exemption from designation. OFAC has designated U.S. citizens and U.S.-organized entities in cases involving sanctions evasion, providing material support to a designated party, or acting on behalf of a sanctioned government or organization. Being a U.S. person creates a compliance obligation; it does not create immunity from being designated if the underlying conduct meets a program’s designation criteria.

Compliance obligations formally apply to U.S. persons, but OFAC’s practical reach extends further. Non-U.S. individuals and entities become subject to specific OFAC requirements when a transaction touches U.S. jurisdiction — for example, when it is denominated in U.S. dollars and clears through the U.S. financial system, involves a U.S. correspondent bank, or involves a U.S.-person employee, officer, or counterparty. An employee working for a U.S.-registered entity is generally treated as acting on behalf of a U.S. person for sanctions purposes, meaning the entity’s compliance obligations extend to that employee’s conduct within the scope of their role, regardless of the employee’s own nationality or location.