OFAC Sanctions: How to Ensure the Safety of International Business Trips
Today, business is not just an office, calls, and documents. It is meetings with partners in other countries, participation in international forums, business trips, and negotiations abroad. Everything seems simple and convenient: you book a ticket, fly, do your work. But behind all this mobility lie risks that are often remembered too late.
One of such risks is the actions of OFAC — the Office of Foreign Assets Control. Even if your company does not work directly with the USA, one wrong name on the passenger list or an accidental payment can lead to very serious consequences: from account blocking to a ban on international transactions.
In this article, we will explain what exactly constitutes sanction risk during business trips, how OFAC rules are structured, and most importantly — how to protect yourself, your team, and your company in advance.
What is OFAC?
OFAC is the Office of Foreign Assets Control of the U.S. Department of the Treasury. Its main task is to implement economic and trade sanctions against countries, organizations, and individuals that the U.S. considers a threat to its security, foreign policy, or economy.
It may seem that this only concerns large corporations working with Iran or North Korea. But in practice, any business can fall under OFAC sanctions — even one that has never directly dealt with the USA. One transaction, counterparty, or mention in the chain is enough — and your company may find itself in a difficult situation: with frozen accounts, fines, or a damaged reputation.
Who falls under the jurisdiction of OFAC
Citizens and companies of the USA
First and foremost, sanction rules apply to all U.S. citizens, including residents, as well as companies registered in the U.S. and their foreign branches.
Foreign companies and banks
But foreign businesses are not insured either. If you use dollars, transfer money through American banks, or have American clients, you already fall under the sanctions jurisdiction of OFAC. Even one payment passing through a correspondent account in New York can lead to an inspection or blocking.
Individuals
And certain individuals — especially top managers, owners, and beneficiaries — may fall under OFAC actions if their actions violate established restrictions.
Types of sanctions
- Country sanctions
These are full or partial bans on trade with certain states (for example, Iran, North Korea, Cuba). They cover almost all types of activities — from export and import to investments and the provision of services. - Individual sanctions (SDN List)
The SDN (Specially Designated Nationals) list includes individuals, companies, vessels, and entities with whom any transactions are prohibited. Working with such a person — even accidentally — can lead to consequences. - Sectoral sanctions
Such measures are applied to specific sectors of the economy — for example, energy or the defense industry. They restrict certain types of transactions rather than completely prohibiting interaction.
Consequences of non-compliance with OFAC sanctions
Ignoring OFAC requirements means exposing your business to serious risk. The consequences may include the following:
- Freezing of assets — bank accounts located within the jurisdiction of the USA can be blocked without warning.
- Fines — amounts can reach millions of dollars, even if the violation occurred unintentionally.
- Criminal liability — in severe cases, especially with proven intent, investigations and lawsuits are possible.
- Reputational losses — making it into the news as a company that violated sanctions — is a blow to the trust of clients and partners.
OFAC and corporate business trips: where sanction risks lie
For many international companies, business trips are a part of everyday work: meetings with partners, participation in forums, negotiations, and contracts. But when it comes to countries under U.S. sanctions, even a standard business trip can lead to serious legal consequences. OFAC (Office of Foreign Assets Control) sanctions extend far beyond the U.S. and can affect any company if it uses dollar transactions, international payment systems, or interacts with sanctioned individuals.
Understanding how OFAC sanctions work in the context of business trips is a key element of corporate compliance.
Where exactly do OFAC risks arise during international travel?
1. Trips to sanctioned countries
Some countries are under comprehensive U.S. sanctions: Cuba, Iran, North Korea, Syria, parts of Ukraine (for example, Crimea), as well as Venezuela. A visit to such a jurisdiction, even as part of a business mission or for humanitarian purposes, may be regarded as a violation of sanctions legislation. Sometimes even transit through such territories can raise suspicion among banks or financial regulators.
2. Payment for services through sanctioned banks
When you book a hotel, rent a conference room, or pay for the services of local contractors, the money passes through financial intermediaries. If one of them is under OFAC sanctions, the funds may be blocked. Even if you were unaware of this, you will not be able to avoid responsibility.
3. Interaction with sanctioned individuals
An invitation to a business meeting with a partner who ended up on the SDN List may be considered a violation of the sanctions regime. The same situation applies to conference participants, suppliers, contractors, and even translators. Checking connections is the key to reducing risks.
4. Export of controlled technologies
During business trips, employees may demonstrate equipment, documents, software. If this falls under export control regulations, and at the same time you are in a sanctioned country, this may already constitute a violation. Even verbal discussions of technical information can sometimes be classified as technology transfer.
5. Risk of funds being blocked
If you paid for a trip and the transaction went through a country or bank associated with sanctions, OFAC may freeze the payment. This could involve both a corporate account and an employee’s personal card. Such cases often require the involvement of lawyers to recover the funds and eliminate the sanction-related consequences.
How to minimize sanction risks in international business trips
Before entering into cooperation with foreign partners, it is essential to conduct due diligence on the destination country, as well as on all counterparties and contractors. Companies should implement an internal OFAC compliance policy for employees working with international partners. Key employees must be trained in the basics of sanctions legislation—what is permitted, what is prohibited, and which actions may be considered violations. If your funds are blocked, it is critical to act without delay, as every lost minute reduces the chances of a favorable outcome.
How specialists in OFAC can help?
They will determine the exact reason for the blocking, contact the bank or directly with OFAC, and prepare a request for obtaining a special license or unblocking the funds. If necessary, they will protect your company’s interests during an investigation and help review your internal compliance system to prevent similar incidents in the future.
Corporate compliance with OFAC sanctions is not just a “paper formality.” It is a real way to protect your business, employees, and partners. The sooner you establish a control system, the more confident you will feel in any international operations or travel.
