4

Where can I find the authoritative, up-to-date list of countries that are currently embargoed by the United States of America?

Note that embargoed is distinct from sanctions. I specifically want to find the list of countries with which US companies are not allowed to do business.

Where can I find this list of countries under US embargo? Not from a third-party, but from the US government source that maintains the list of embargoed nations?

1
  • 7
    Explain how you define the difference between embargo and sanction. Are you referring to "absolute, universal exceptionless prohibition against transactions?" Not even North Korea or Cuba are subject to an absolute transaction ban.
    – user6726
    Oct 1 at 20:22

2 Answers 2

6

The US government is not required to publish a single list of "embargoed" countries, however defined. They are, however, required to publish the legal underpinnings of any restriction. This takes two forms. First, Congress must pass some law that enables the restriction. This page hosted by the Senate explains how to find such laws, however, it only goes back so far. You can find all of the US Code on the House US Code website. Usually, any change of sanctions don't require new legislation. The second set of publications are executive orders and executive-branch regulations, which are published in The Federal Register. For example, this is an executive order (February 21, 2022) regarding blocking of certain persons and transactions related to Russia's invasion of Ukraine. The Bureau of Industry and Security, Department of Commerce then published an implementation of that order, which is published in the Federal Register. The Office of Foreign Assets Control, Dep't of Treasury later published licenses related to this.

The obvious problem is that hundreds of pages of information are published in the Federal Register every day, so keeping up with the rules is challenging. A partial substitute would be to check the web page of each department that might be involved in promulgating such regulations. The Dept. of Treasury has pages on financial sanctions. One thing they provide is useful information about is list of countries that you need to worry about in terms of U.S. sanctions: there is no list. As they explain,

U.S. sanctions programs vary in scope.Some are broad-based and oriented geographically (i.e. Cuba, Iran).Others are “targeted” (i.e. counter-terrorism, counter-narcotics) and focus on specific individuals and entities.These programs may encompass broad prohibitions at the country level as well as targeted sanctions.Due to the diversity among sanctions, we advise visiting the “Sanctions Programs and Country Information” page for information on a specific program.

OFAC’s Specially Designated Nationals and Blocked Persons List (“SDN List”) has approximately 6,300 names connected with sanctions targets. OFAC also maintains other sanctions lists which have different associated prohibitions. Many individuals and entities often move internationally and end up in locations where they would be least expected.Accordingly, U.S. persons are prohibited from dealing with SDNs regardless of location and all SDN assets are blocked.Entities that an SDN owns (defined as a direct or indirect ownership interest of 50% or more) are also blocked, regardless of whether that entity is separately named on the SDN List. Because OFAC's programs are dynamic, it is very important to check OFAC's website regularly.Ensuring that your sanctions lists are current and you have complete information regarding the latest relevant program restrictions is both a best practice and a critical part of your due diligence responsibility.

The Dep't of Commerce has a less-useful list, the entities list, and also a Trade Enforcement web page.

You should note that sanctions against the Central African Republic stem from Executive Order 13667 of May 12, 2014, but the Dept. of Treasury amended the regulations as of September 29, 2022 not in response to a new executive order. This is reflected on the Treasury Dep't web page on sanctions. It is unknown, and perhaps unknowable, whether the Dept. of Commerce will promulgate any foreign sanctions regulation that are not mirrored on the Treasury Dept. web page. In the case of the CAR sanctions, the executive order directed Treasury to write rules, though the Sec'y of State also received ordered (not related to financial sanctions).

1

The U.S. Department of State’s office of Economic Sanctions Policy and Implementation has a list of Economic Sanctions Programs.

Your Answer

By clicking “Post Your Answer”, you agree to our terms of service, privacy policy and cookie policy

Not the answer you're looking for? Browse other questions tagged or ask your own question.