Glossary

What is an Embargoed Jurisdiction?

A country or region subject to comprehensive US sanctions that broadly prohibit transactions involving that jurisdiction.

Definition

Comprehensive sanctions regimes apply to the governments and often the entire territory of Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine. Recent additions include sanctions against the Russian energy and financial sectors.

Regulatory context

OFAC maintains comprehensive embargoes against certain jurisdictions meaning all transactions with that jurisdiction are broadly prohibited unless specifically authorized by OFAC license.

Who it affects

Any US person (individual or entity) is prohibited from engaging in transactions involving embargoed jurisdictions. Non-US persons can also face secondary sanctions for certain dealings.

Relevance to AI agents

AI agents routing payments or services must check destination jurisdictions before processing. An agent paying an IP address or bank account in an embargoed region triggers the same violation as a human doing so.

agentmail coverage

agentmail checks destination countries against 16 comprehensively sanctioned jurisdictions and returns a flag if the counterparty is in an embargoed region.

FAQ

1. How many comprehensively sanctioned jurisdictions are there?

OFAC currently lists 5 comprehensive embargoes: Cuba, Iran, North Korea, Syria, and the Crimea/Donetsk/Luhansk regions of Ukraine. Additional sectoral sanctions apply to Russia, Belarus, Venezuela, and others.

2. Can my agent do business in a sanctioned jurisdiction with a license?

Yes. OFAC can issue specific licenses authorizing certain transactions. Your agent should be configured to check for an active license before proceeding, and agentmail screening provides the evidence trail.

3. Does jurisdiction screening apply to IP addresses?

Yes. OFAC guidance indicates that facilitating transactions with persons in embargoed jurisdictions including through IP geolocation-based services can constitute an export of services to that jurisdiction.

Related glossary terms

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