OFAC FAQ 11: who must comply with US sanctions (OFAC, Frequently Asked Question 11)
A US company that buys a licence from a holder abroad has to comply with OFAC rules on that payment, wherever the holder is.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“All U.S. persons must comply with OFAC sanctions, including all U.S. citizens and permanent residents regardless of where they are located, all individuals and entities within the United States, and all U.S. incorporated entities and their foreign branches.”
Where it was read
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide