A tariff makes something more expensive. A sanction makes it a federal offence.
That distinction is worth holding onto, because almost every instinct an importer has built over the last two years is a tariff instinct. When a duty appears you model it, you renegotiate, you re-source, you decide whether the margin still works. All of that is arithmetic, and all of it assumes there is a number.
Sanctions do not have a number. There is no rate at which the transaction becomes acceptable, which makes a sanction closer to an import ban than to a duty.
Two Different Things Are Called Sanctions
This is where the confusion sits, and the two mechanisms behave completely differently.
The first is a country programme. The target is a place. Broadly speaking, transactions involving that jurisdiction are prohibited unless something specifically authorises them, and the questions you are asking are questions of geography: where is this made, where is the money going, whose flag is on the vessel. Iran, Cuba and North Korea are the long-standing examples, along with the occupied regions of Ukraine. The Office of Foreign Assets Control at the U.S. Treasury, usually shortened to OFAC, publishes every active programme with its regulations and general licences (ofac.treasury.gov).
The second is a designation. The target is a person or a company, and it carries no geography at all. OFAC names specific individuals and entities, and dealing with any of them is prohibited wherever they happen to be. A designated party can sit in a country with no sanctions programme whatsoever, in a jurisdiction you have traded with comfortably for a decade, behind an ordinary company name that tells you nothing.
That difference matters more than anything else here. Country programmes are the ones every importer has heard of, and they are mostly avoidable by knowing where you buy from. Designations are the ones that actually catch people, because there is no country to avoid. The only defence is knowing precisely who is on the other side of the transaction.
An importer who has confirmed they do not buy from Iran has answered the easy question and left the hard one untouched.
Syria Shows Why "Is That Country Sanctioned?" Is the Wrong Question
Syria is the clearest worked example available, and it doubles as a warning about relying on what you knew a year ago.
For years Syria was a comprehensive country programme. Then it was dismantled. Executive Order 14312, Providing for the Revocation of Syria Sanctions (federalregister.gov), revoked six foundational executive orders, and in OFAC's own words the economic sanctions administered by OFAC that constitute the Syria Sanctions Program are no longer in effect as of July 1, 2025 (ofac.treasury.gov). The programme itself is now filed under inactive and archived (ofac.treasury.gov). The Caesar Syrian Civilian Protection Act was subsequently repealed by Congress, and on August 24, 2026 the Secretary of State rescinded Syria's designation as a State Sponsor of Terrorism (state.gov), a step also recorded in the Federal Register (federalregister.gov).
So the country programme is gone. Syria is not a comprehensively sanctioned jurisdiction.
And yet, alongside that same executive order, OFAC designated 139 persons. Bashar al-Assad and his associates, human rights abusers, captagon traffickers and other actors remain sanctioned as individuals and entities, now administered under a programme called Promoting Accountability for Assad and Regional Stabilization Sanctions (ofac.treasury.gov). OFAC also notes that violations occurring before July 1, 2025 can still be investigated and enforced.
Read that sequence again, because it contains the whole lesson. The country stopped being sanctioned. Specific parties inside it did not. An importer who took from the headlines that Syria is open, and did not screen the counterparty, has drawn precisely the wrong conclusion from entirely correct information.
The Part That Actually Catches People
The mechanism for designations is a list, and the risk is what the list does not show you.
OFAC maintains the Specially Designated Nationals and Blocked Persons List (ofac.treasury.gov), universally called the SDN list, and it is searchable directly (sanctionssearch.ofac.treas.gov). Dealing with anyone on it is prohibited. That much is straightforward, and checking a name takes seconds.
Then there is the Fifty Percent Rule (ofac.treasury.gov), and this is the one to understand properly.
In OFAC's own words, entities owned fifty per cent or more in the aggregate by one or more blocked persons are considered blocked. Read the phrase in the aggregate carefully. If one blocked person owns twenty-five per cent of a company and a different blocked person owns another twenty-five per cent, that company is blocked, and it appears on no list anywhere.
There is a limit, and it cuts the other way. An entity that is controlled by blocked persons but not owned fifty per cent or more is not automatically blocked, though OFAC can designate it separately.
The practical meaning is uncomfortable. Screening your supplier's name against the SDN list is necessary and it is not sufficient, because the entity that is blocked by operation of that rule returns a clean result every single time.
There Is No Intent Requirement
This surprises people who assume acting in good faith is a defence.
OFAC civil enforcement operates on strict liability. You do not have to know your counterparty was blocked. You do not have to have intended anything. Poor diligence does not excuse the violation; it is closer to being the point. Civil penalties are assessed per violation and scale with the value of the transactions, and the statutory maximums are adjusted for inflation rather than fixed.
Wilful violations are a different matter again. Under section 1705 of title 50 of the United States Code (law.cornell.edu) they are criminal, carrying fines of up to a million dollars and up to twenty years of imprisonment.
Where an Importer Actually Gets Caught
Rarely by buying from a sanctioned country. Almost always through a designated party at one remove.
A trading company with an owner nobody asked about. A new bank account in a third country for an existing supplier, which is the most common warning sign there is and the easiest to wave through when a shipment is waiting. A component supplied into your factory from somewhere you never examined. A vessel or a logistics provider. An agent taking commission whose own ownership you have never seen.
None of those look like sanctions problems while they are happening. They look like ordinary friction.
What Screening Actually Involves
Screen against more than one list. The Consolidated Screening List at the Department of Commerce (trade.gov) brings the Treasury, Commerce and State Department lists together in one place, and each carries its own legal obligation. The SDN list alone is not the whole of it.
Screen more than the supplier. The manufacturer, the trading company, the bank, the freight forwarder, the agent, and wherever you can establish it, the ownership behind each.
Screen more than once. Lists change constantly, and OFAC publishes designations and removals as they happen (ofac.treasury.gov). A counterparty who was clean at onboarding may not be clean at the next payment, and the payment is the moment that matters.
Ask about ownership directly, and write down the answer. The Fifty Percent Rule cannot be satisfied by a list check, so the only evidence available is what you asked and what you were told.
And keep the record. Under strict liability the record is not a defence to the violation itself, but demonstrable diligence is what mitigation is built from, and mitigation is the difference between an expensive year and a catastrophic one.
The Moral
Everything else in this business is a cost you can model. Sanctions are a boundary you either stayed inside or did not.
That makes them unlike tariffs in the way that matters most: there is no version of the analysis where you weigh the penalty against the margin and decide it is worth it. The correct posture is not optimisation. It is knowing who is on the other side of the transaction, which is a question most importers can answer about their factory and very few can answer about the factory's owner.
Checking What Is Current
This article describes the position as at September 10, 2026, and Syria above is the reason that sentence is not boilerplate. Sanctions move faster than anything else in trade. Programmes are created and revoked, designations are added and removed weekly, and general licences change what is permitted without the underlying programme changing at all. Anything written about sanctions has a shelf life, this article included.
Check these rather than any article.
• OFAC sanctions programs and country information — OFAC sanctions programs and country information, the authoritative list of what exists right now
• Sanctions List Search — Sanctions List Search, for checking a specific name or entity
• Consolidated Screening List — The Consolidated Screening List, spanning Treasury, Commerce and State
• OFAC Recent Actions — OFAC Recent Actions, where designations and removals are published as they happen
• OFAC frequently asked questions — OFAC frequently asked questions, including the Fifty Percent Rule and country guidance
• State Department sanctions and designations — The State Department's sanctions and designations pages, for the diplomatic measures that sit alongside the Treasury programmes
This is general commentary and not legal advice. Sanctions law is technical, it changes frequently, and the consequences are severe enough that a specific question deserves a specialist rather than an article. Consult qualified sanctions counsel about your own counterparties, and rely on OFAC's own publications rather than any summary of them, this one included.
So — when you onboard a new supplier, what are you screening them against, and are you screening the ownership behind them or only the name on the invoice? And where does the evidence of that check live once it is done?