UNICORN PRIVATE Sanctions compliance in the United States: which rules apply and what companies must do
In short
In the United States, sanctions are based mainly on the International Emergency Economic Powers Act (IEEPA) and on executive orders.
The Office of Foreign Assets Control of the US Treasury administers sanctions, and the Bureau of Industry and Security (BIS) handles export controls.
US persons must block the property of listed parties and should screen clients and suppliers regularly.
Applicable rules and competent authorities
The International Emergency Economic Powers Act (IEEPA) and the executive orders of the President are the main legal basis, together with the regulations in Title 31 of the Code of Federal Regulations.
The Office of Foreign Assets Control of the US Treasury administers economic sanctions and publishes the Specially Designated Nationals (SDN) list. Civil liability applies even without intent.
The Bureau of Industry and Security (BIS) of the Department of Commerce administers the Export Administration Regulations (EAR) and the Entity List. Rules can also reach non US companies, for example when they use US dollars or export items of US origin.
Practical duties for companies
- Block the property and interests in property of listed persons and do not deal with them.
- Screen clients, suppliers, owners and banks against the SDN list and the other US lists, also when they change.
- Treat entities owned 50% or more by listed persons as blocked too.
- Check whether your items need an export licence under the EAR.
- Keep records of the checks and transactions for 10 years, as required by 31 CFR 501.601.
Fines and penalties
Statutory maximums we verified on the official texts:
- United States, OFAC: up to $377,700 per violation or twice the value of the transaction; criminal penalties up to $1,000,000 and 20 years in prison. (source)
- United States, BIS (export controls): up to $374,474 per violation or twice the value of the transaction. (source)
Maximum amounts set by law, as published by the authorities linked, checked on October 29, 2026.
Official sources
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Frequently asked questions
Who administers sanctions in the United States?
The Office of Foreign Assets Control of the US Treasury administers economic sanctions. The Bureau of Industry and Security (BIS) handles export controls.
Do US sanctions apply to non US companies?
They can. US rules apply to US persons, and also to transactions that involve the US financial system, US dollars or items of US origin.
What are the penalties for breaching US sanctions?
Breaches can lead to civil penalties, even without intent, and to criminal penalties. The figures we verified on the official texts are shown on this page.
The program can make mistakes. The final responsibility for compliance stays with your company. Unicorn Intelligence is an information tool. Decisions and legal obligations, including sanctions compliance, due diligence and tender participation, remain with the customer.
Unicorn Intelligence checks your clients and suppliers against the sanctions lists every day.