What Are Secondary Sanctions?

Secondary sanctions explained - and why jurisdiction does not exempt your agent.

TL;DR

TL;DR: Primary sanctions prohibit US persons from transacting with designated parties. Secondary sanctions extend the reach - foreign persons can face designation for significant transactions with sanctioned parties, even with no US nexus.

The distinction

Primary: US persons, US-origin goods, USD transactions. Secondary: non-US persons who facilitate or materially support sanctioned activity - banking, trading, or clearing for designated parties.

Why it matters for agents

An agent operating outside the US is not automatically outside OFAC's reach. A payment agent that clears for a sanctioned party can create secondary-sanctions exposure for its operator.

The posture

Screen counterparties against the SDN list and applicable international lists, document controls, fail closed. The same stack, whichever jurisdiction you operate from.