OFAC publishes "Introduction to the Office of Foreign Assets Control" guide

The US Office of Foreign Assets Control (OFAC) published a new guide on 1 June 2026, highlighting important baseline information on US sanctions and OFAC’s compliance expectations.

The guide provides a basic overview of US sanctions regulations and how to comply with them. The guide also provides links to more detailed guidance produced by OFAC on specific topics, making it easier to find information which is found elsewhere on OFAC’s website and in its FAQs. 

What does this guide contain?

It contains general information for US- and non-US persons on:

• The different sanctions programs and types of sanctions, including list-based sanctions, jurisdiction-based sanctions (e.g., on Cuba), sector-based sanctions (e.g., on the Russian energy sector), and secondary sanctions (which target non-US persons)—providing an important reminder that prohibitions may operate differently depending on the program;
• The Specially Designated Nationals and Blocked Persons List (SDN List)—which lists individuals, companies, aircraft and vessels targeted by US sanctions;
• Which individuals/entities must comply with US sanctions (noting that programs may apply US sanctions to non-US persons);
• How to comply with US sanctions, e.g., through effective organizational compliance programs and internal sanctions controls, as well as reporting and recordkeeping requirements;
• Licenses from OFAC, which authorize activity which would otherwise be prohibited under US sanctions; and
• OFAC’s sanctions enforcement procedures and potential outcomes of such procedures.

In particular, the guide encourages organizations subject to US jurisdiction to develop, implement, and routinely update a risk-based sanctions compliance program.  The guide reminds readers that effective sanctions compliance programs are tailored to each individual organization and contain five essential components:

• Management commitment;
• Risk assessment;
• Internal controls;
• Testing and auditing; and
• Training.

More information on developing an effective sanctions compliance program is provided in OFAC’s Framework for OFAC Compliance Commitments.

Key takeaways

OFAC’s statement that it published this guide to “strengthen[] the effectiveness of OFAC sanctions” underscores the importance of understanding and complying with US sanctions where there is a US nexus, particularly in view of OFAC’s strict liability standard for imposing civil penalties on sanctions violators.

The guide may assist companies which have limited experience with OFAC and with navigating US sanctions (such as smaller companies, non-US person companies, and foreign individuals subject to US sanctions) access baseline information on US sanctions.