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QuestionOct 4, 2020 - 7:28

What’s the difference between US primary and secondary sanctions, and how do I know which ones are relevant to me?

i want to make sure I don’t violate the US primary sanctions that will remain in place


Saba Bagherzadeh

New York City, United States

Oct 10, 2020 - 18:15

The primary sanctions are related to the various OFAC sanctions against countries, entities, individuals, and activities that have a US nexus. The secondary sanctions are related to the non-US citizens who engage in specific activities involving targeted countries, entities, and individuals without a US nexus. If your activities have a US nexus, such as involving the US dollar you may be subject to the US primary sanctions. To see if you would not be subject to the secondary sanctions, it depends on the kind of your business and your transactions.


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