Secondary Sanctions

Sanctions that reach non-US persons for activity involving sanctioned countries or entities, even where no US nexus exists.

TL;DR

TL;DR: Secondary sanctions apply pressure to non-US persons who deal with sanctioned targets, regardless of any US connection. They expand reach beyond primary sanctions on US persons.

Primary Versus Secondary

Primary sanctions bind US persons and transactions with a US nexus. Secondary sanctions go further: they target non-US persons for activities involving sanctioned countries or entities, even when no US person or jurisdiction is involved. The goal is to discourage foreign parties from doing business with designated targets.

Why They Change Screening Scope

Secondary sanctions mean a non-US counterparty is not automatically out of scope. An entity that deals with a sanctioned country can itself become a target, which is why screening has to look at more than direct SDN List matches and consider the counterparty's relationships.

Agent Payment Relevance

An AI agent settling payments globally faces a counterparty set that spans many jurisdictions. sanctionsai.dev screens across 16 jurisdictions and 19,218 SDN names, which helps surface the parties that secondary sanctions put at risk. Money movers such as x402, AP2, ACP, and Coinbase AgentKit transfer funds but do not screen, so the screening step must be added separately.

Practical Guidance

• Do not assume non-US counterparties are out of scope.
• Screen the counterparty and its known relationships, not just the name.
• Re-check periodically, since secondary designations change.