Glossary
Secondary Sanctions
Sanctions exposure that extends to non-US persons for specified conduct with designated parties, even without US jurisdiction.
Definition
Secondary sanctions are measures that can be imposed on non-US persons — individuals or entities not otherwise subject to US jurisdiction — for engaging in specified conduct with designated parties. They extend US sanctions pressure beyond US persons.
Regulatory context
Secondary sanctions are program-specific and not automatic. Notable authorities include Iran (IFCA), Russia (CAATSA), and North Korea. A non-US person designated under secondary sanctions can be cut off from the US financial system and from USD transactions.
Who it affects
Non-US crypto exchanges, VASPs, and any non-US business whose counterparties include designated persons under a program with secondary-sanctions authority.
Relevance to AI agents
Agents operated by non-US entities are not immune. If the counterparty is designated under a program with secondary-sanctions authority (Iran, Russia, North Korea), the non-US operator can be exposed even without US nexus.
SanctionsAI coverage
SanctionsAI flags program tags on matches, including Iran, Russia-EO14024, and North Korea designations — the programs most associated with secondary-sanctions exposure.
FAQ
1. Do secondary sanctions apply to non-US companies?
Yes, for specified conduct with designated parties under programs that carry secondary-sanctions authority (notably Iran, Russia, North Korea).
2. Are secondary sanctions automatic?
No. They are discretionary and program-specific, but the exposure is real and should be screened for.
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