Does OFAC apply to non-US companies?

OFAC reaches non-US companies when a US nexus exists, and secondary sanctions extend pressure even further.

TL;DR

TL;DR: OFAC applies to non-US companies when there is a US nexus: US persons, US dollars, US goods, or US technology involved. Secondary sanctions extend further.

What a US nexus means

OFAC jurisdiction attaches through specific connections. If a non-US company has US employees, transacts in US dollars, ships US-origin goods, or uses US technology, OFAC rules can reach it. Any of these connections is enough to make the company subject to the same prohibitions and penalties as a domestic firm, with civil penalties starting at over $350,000 per violation.

Where secondary sanctions come in

Even without a direct US nexus, OFAC can impose secondary sanctions on non-US parties that do material business with certain sanctioned targets, such as designated persons or jurisdictions. These measures can cut a company off from the US financial system, which is a severe commercial risk even for firms with no US office.

Practical takeaways

• Assume OFAC applies if any dollar, US person, or US technology is involved.
• Screen counterparties before transactions regardless of where your company is based.
• Use a screening API like sanctionsai.dev to check wallets and names in under 100 ms.

Geography is not a shield; screening is the only reliable control.

The conservative rule is to treat any touchpoint with US dollars, US persons, or US technology as bringing the company under OFAC's reach.