Sanctions are one regime among several
People use the phrase loosely, but U.S. trade restrictions come from different sources. Economic and trade sanctions administered by OFAC at the Treasury Department block dealings with listed persons and restrict business involving certain countries. Export controls are a separate system: the Commerce Department's Bureau of Industry and Security controls many commercial and dual-use items and maintains lists such as the Entity List, while the State Department controls defense articles. Tariffs and import duties are another matter again, administered at the border by Customs and Border Protection. One transaction can trigger more than one of these at once, and a license under one regime does not answer the question under another.
When U.S. measures reach companies abroad
U.S. sanctions can matter even to a company with no U.S. office. Dollar payments usually clear through U.S. banks, and U.S.-origin components, software, or technology can bring a foreign-made item under U.S. export rules. The United States also uses secondary sanctions, aimed at discouraging foreign companies from dealing with targeted parties, where the risk is typically being cut off from the U.S. market or being designated rather than a penalty for breaking a rule that binds you directly. Other governments, including the European Union, the United Kingdom, and Korea, run their own measures that overlap with U.S. sanctions without matching them. Exporters selling to U.S. buyers are often asked to certify compliance, and those certifications can become contract obligations.
Questions for a first review
We usually begin with the facts of the trade: what is being sold, where it goes, who ends up using it, and how payment travels. Product classification often decides whether export controls apply, and the end use and end user can matter as much as the destination. If a shipment or payment has already been stopped, we look at what the bank, freight forwarder, or agency has said and whether a report, a license request, or a disclosure needs to be considered. We also discuss contract terms with counterparties, such as sanctions representations and termination rights, since new measures can arrive with little warning. The goal is a clear sense of which rules apply to the deal in front of you.
