OFAC (the Office of Foreign Assets Control) is the U.S. Treasury bureau that enforces economic and trade sanctions. It administers the SDN list, issues general and specific licenses, and can impose penalties of up to $20 million per violation. Here’s how it works and what it means for you.
OFAC is a bureau within the U.S. Department of the Treasury responsible for:
Comprehensive embargo since 1962. Cuban Assets Control Regulations (31 CFR Part 515). Prohibits nearly all trade, investment, travel, and financial transactions. 12 general-license travel categories.
ComprehensiveComprehensive sanctions. Iranian Transactions and Sanctions Regulations (ITSR). Prohibits most trade and financial transactions. Secondary sanctions on non-U.S. persons.
ComprehensiveTargeted and sectoral sanctions since 2014 (expanded 2022). Blocks major Russian banks, energy companies, oligarchs. Secondary sanctions on military-industrial supplies.
Targeted + SectoralComprehensive embargo. Nearly total trade and financial isolation. Heavy secondary sanctions enforcement against facilitators.
ComprehensiveTargeted sanctions on individuals and PdVSA (state oil). General License 44 authorizes certain oil transactions by Chevron. Evolving program.
TargetedComprehensive embargo. Syrian Sanctions Regulations. Caesar Syria Civilian Protection Act adds secondary sanctions.
ComprehensiveOFAC administers 30+ programs total, including counter-terrorism (SDT/SDGT), counter-narcotics (Kingpin Act), cyber, non-proliferation, and more.
| Type | Maximum Penalty | Notes |
|---|---|---|
| Civil (strict liability) | Up to ~$330,000 per violation or twice the transaction value | No intent required. “Should have known” standard. Most common enforcement. |
| Criminal (willful) | Up to $20,000,000 fine + 20 years imprisonment | Requires willful violation. DOJ prosecution. Rare for individuals; used for institutional evasion. |
| Warning / no-action letter | $0 | First-time, low-value, self-disclosed. Most common outcome for individual travelers. |
Notable settlements: BNP Paribas ($963M, 2014 — Cuba/Sudan/Iran), Société Générale ($54M, 2018 — Cuba), Standard Chartered ($1.1B, 2019 — Iran/Cuba/Myanmar).
Cuba is one of OFAC’s comprehensive sanctions programs — meaning virtually all transactions are prohibited unless specifically authorized. Key Cuba-specific OFAC tools:
OFAC stands for the Office of Foreign Assets Control. It is a bureau within the U.S. Department of the Treasury, headquartered in Washington, D.C. OFAC was established in 1950 (successor to the WWII-era Office of Foreign Funds Control) and is responsible for administering and enforcing U.S. economic and trade sanctions.
OFAC compliance refers to the processes businesses use to ensure they do not violate U.S. sanctions. This typically includes: screening customers, counterparties, and transactions against the SDN list; implementing a written sanctions compliance program (SCP); training employees; conducting due diligence on new business relationships; filing blocked-property or rejected-transaction reports; and self-disclosing any potential violations. Banks, fintech companies, exporters, insurers, law firms, and any business with international exposure must maintain OFAC compliance.
Yes. Cuba is under one of OFAC’s most restrictive programs — a comprehensive embargo enforced through the Cuban Assets Control Regulations (31 CFR Part 515). Nearly all trade, investment, travel, and financial transactions between U.S. persons and Cuba are prohibited unless specifically authorized by a general license or individual specific license. Cuba is also designated as a State Sponsor of Terrorism, which compounds banking and aid restrictions.
Penalties depend on severity: warning letters for minor, self-disclosed violations; civil monetary penalties up to ~$330,000 per violation (or twice the transaction value, whichever is greater) under strict liability; and criminal prosecution for willful violations (up to $20 million fine and 20 years imprisonment). OFAC considers factors like voluntary self-disclosure, compliance program quality, cooperation, and remediation when determining penalties.
Use OFAC’s official Sanctions List Search tool on treasury.gov, or use our Cuba SDN checker for Cuba-specific searches with fuzzy matching. For comprehensive compliance, many organizations use commercial screening tools (Dow Jones, Refinitiv World-Check, LexisNexis) that integrate the SDN, sectoral lists, non-SDN lists, and international sanctions from the EU, UK, and UN.
Increasingly, yes. “Secondary sanctions” allow OFAC to penalize non-U.S. persons who facilitate significant transactions with sanctioned parties. This is most aggressively enforced for Iran and Russia programs. For Cuba, secondary sanctions are limited, but any transaction that touches the U.S. financial system (USD clearing, U.S. correspondent banks) brings non-U.S. parties under OFAC jurisdiction. The EU, UK, and Canada have their own sanctions regimes that non-U.S. persons must also comply with.