The CAPTA list was created in March 2019 to implement certain trading restrictions on foreign financial institutions which are subject to correspondent or payable-through account sanctions pursuant to the Ukrainian, Russian, Iranian and Lebanon sanctions programmes.
Sanction Name
CAPTA Sanctions
First Imposed
Last updated
Targets
Trade Restrictions:
Restrictions vary from entity to entity. The CAPTA List specifies the specific prohibition or strict conditions to which the foreign financial institutions are subject.
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The US has operated sanctions programmes targeting major narcotics suppliers, primarily in Latin America, since the mid-1990s.
On 13th December 2023 the US renewed Executive Order 14059 for a further year, until 15th December 2024.
On 10th September 2024, OFAC sanctioned nine Mexican nationals and 26 Mexico-based entities linked to a fuel theft network that generates tens of millions of dollars benefiting the Cartel Jalisco Nueva Generacion (CJNG), a Mexico-based drug trafficking organization responsible for a significant proportion of fentanyl and other deadly drugs trafficked into the United States.
On 24th September 2024, OFAC sanctioned five Colombian nationals and two Mexico-based businesses, including the leaders within Colombia’s Clan del Golfo (CDG)—also known as Los Urabeños—which is one of the country’s largest drug trafficking organizations and a key contributor to human smuggling through the Darién Gap.
On 31st October 2024, OFAC sanctioned five Mexican nationals and two Mexico-based entities linked to La Linea, a violent Mexico-based drug trafficking organization responsible for trafficking fentanyl and other deadly drugs into the United States.
On 19th November 2024, OFAC sanctioned a network of nine Mexican nationals involved in fentanyl, heroin, and other deadly drug trafficking and money laundering. Individuals designated in this network also engage in human smuggling in furtherance of their drug trafficking activities.
On 26th November 2024, OFAC designated five Mexican individuals associated with the Gulf Cartel, one of Mexico’s most dangerous criminal organizations. Those designated today are tied to the Gulf Cartel’s involvement in criminal activities associated with illegal, unreported, and unregulated (IUU) fishing, human smuggling, and narcotics trafficking in the Gulf of Mexico.
Sanction Name
Narcotics Sanctions Program
First Imposed
Last updated
Targets
Specially Designated National:
• Any foreign person determined to be involved in international narcotics trafficking or supporting such activities.
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A range of counter terrorist sanctions programmes have been imposed by the UN and in a number of global jurisdictions, intensifying in the years following the 2001 attacks on New York by Al-Qaeda and the US-led invasion of Iraq in 2003.
Sanction Name
UN Sanctions for Preventing Terrorism
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo and Travel Ban:
• Persons and entities deemed to be linked to or supporting Al-Qaeda or ISIS/Daesh.
Exemptions
1. The travel ban does not apply where entry or transit is necessary for the fulfilment of a judicial process.
2. Exemptions to the Asset Freeze for basic and extraordinary expenses may be applied by the Daesh and Al Qaida Sanctions Committee on a case by case basis.
On 8th October 2024, the EU extended its sanctions programme against ISIL/Da’esh and Al Qaeda for a further year until 31st October 2025.
Sanction Name
Restrictive Measures Directed Against Certain Persons And Entities With A View To Combating Terrorism
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo and Travel Ban:
• Those determined to be involved in the preparation, carrying out or funding of acts of terrorism, including any entities deemed to be associated with Al-Qaeda, Osama bin Laden, ISIS/Daesh or the Taliban. Includes prohibitions on travel and the provision of arms or related materiel to these entities.
Exemptions
1. Travel ban exemptions can be granted on a case-by-case basis on humanitarian grounds, for the purpose of a judicial process or where a member state is bound by an obligation towards an international organisation.
2. Asset freeze exemptions are also permitted for humanitarian purposes, basic expenses, the provision of legal and professional services, fees for holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments dated before the party in question was listed.
Sanction Name
Measures against entities linked to Osama bin Laden, the Al-Qaeda group or the Taliban
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo and Travel Ban:
• Persons and entities linked to Osama bin Laden, Al-Qaeda or the Taliban. This programme includes a prohibition on the supply of arms and related material and travel bans.
Exemptions
1. Asset freeze exemptions can be granted to protect Swiss interests or prevent cases of rigor. Travel ban exemptions may be granted to protect Swiss interests.
On 11th September 2024, OFAC designated three individuals, five companies, and two vessels that are involved in smuggling oil and liquified petroleum gas (LPG) to generate revenue for Hezbollah. The network, comprised of Lebanese businessmen and companies and overseen by a senior leader of Hezbollah’s finance team, has facilitated dozens of LPG shipments to the Government of Syria and channelled the profits to Hezbollah.
On 25th September 2024, OFAC designated more than a dozen entities and vessels for their involvement in the shipment of Iranian crude oil and liquid petroleum gas to Syria and East Asia on behalf of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Hezbollah.
On 2nd October 2024, OFAC sanctioned one individual and three companies that have facilitated weapons procurement and smuggling operations for Ansarallah, commonly known as the Houthis. The action targeted key procurement operatives and suppliers located in Iran and the People’s Republic of China (PRC) that have enabled the Houthis to acquire dual-use materials and components needed to manufacture, maintain, and deploy an arsenal of advanced missiles and unmanned aerial vehicles (UAVs) against U.S. and allied interests.
On 7th October 2024, OFAC designated three individuals and one sham charity that are prominent international financial supporters of Hamas, as well as one Hamas-controlled financial institution in Gaza. OFAC also designated a longstanding Hamas supporter and nine of his businesses.
On 15th October 2024, OFAC took joint action with Canada against the Samidoun Palestinian Prisoner Solidarity Network, or “Samidoun,” a sham charity that serves as an international fundraiser for the Popular Front for the Liberation of Palestine (PFLP) terrorist organisation. OFAC also designated Khaled Barakat, a member of the PFLP’s leadership.
On 16th October 2024, OFAC sanctioned three individuals and four associated companies involved in a Lebanon-based sanctions evasion network that generates millions of dollars in revenue for Hezbollah.
On 17th October 2024, OFAC sanctioned eighteen companies, individuals, and vessels for their ties to Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF)-backed Houthi financial official Sa’id al-Jamal (al-Jamal) and his network. Included in this action are the captains of vessels transporting illicit oil as well as the companies that managed and operated these ships.
On 14th November 2024, OFAC sanctioned 26 companies, individuals, and vessels associated with the Al-Qatirji Company, a Syrian conglomerate responsible for generating hundreds of millions of dollars in revenue for Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and the Houthis through the sale of Iranian oil to Syria and the People’s Republic of China (PRC). Previously designated for its role in facilitating the sale of fuel between the Syrian regime and the Islamic State of Iraq and Syria (ISIS), the Al-Qatirji Company has morphed into one of the main channels through which the IRGC-QF generates revenue and funds its regional proxy groups. OFAC is expanding its targeting of Al-Qatirji’s network and its fleet of vessels to inhibit the IRGC-QF from benefiting from this relationship.
On 19th November 2024, OFAC designated six senior Hamas officials, including the terrorist group’s representatives abroad, a senior member of the Hamas military wing, the Izz Al-Din Al-Qassam Brigades, as well as individuals involved in supporting the terrorist group’s fundraising efforts and weapons smuggling into Gaza.
Sanction Name
Executive Orders Blocking Property and Prohibiting Certain Transactions
SANCTIONS
First Imposed
Last updated
Targets
Specially Designated National:
• Foreign persons determined to have committed or to pose a significant risk of committing acts of terrorism that threaten the security of US nationals or the national security, foreign policy or economy of the US and those providing material support to such activities.
Exemptions
1. OFAC authorises certain transactions, the majority of which relate to activities concerning the Palestinian authority, concerning such areas as travel, employment, residence and maintenance; for the payment of taxes and incidental fees; and if they are necessary for the conclusion of activities with the Authority. US persons are also permitted to donate medicine to the Palestinian Authority and authorised to engage in transactions with several entities and individuals within the Palestinian Authority Presidency, Palestinian Judiciary and Palestinian Legislative Council.
2. OFAC permits humanitarian transactions in Iran with the direct or indirect involvement of the Central Bank of Iran.
3. OFAC also permits payments from funds originating from outside the United States for the provision of certain legal services to or on behalf of blocked persons. Transactions involving property and interests in the property of the Government of Iran or Iranian financial institutions are also authorised.
4. General Licence 8, introduced on 27th February 2020, permits certain humanitarian transactions that involve the Central Bank of Iran, which is designated as a terrorist organisation by OFAC.
5. On 10th December 2021 OFAC issued General License 16 which authorised transactions involving the Taliban or the Haqqani Network that are necessary to the transfer of non-commercial personal remittances to Afghanistan.
6. On 22nd December 2021 OFAC issued General Licenses 17, 18, and 19 adding to the exemption for personal remittance an exemption for the provision of humanitarian assistance to a range of civil society bodies under the control of the Taliban or Haqqani network.
7. On 15th November 2022 OFAC issued General License 21 authorising limited safety and environmental transactions involving certain vessels that are prohibited by the Global Terrorism Sanctions Regulations. On 14th December 2022 OFAC issued General License 21A updating the exemptions laid out in General License 21.
8. On 12th January 2023 OFAC issued General License 21B, authorising until 13th April 2023 limited safety and environmental transactions involving certain individuals and vessels which are subject to Global Terrorism Sanctions Regulations. This includes transactions necessary to the safe docking and anchoring of any of the sanctioned vessels in port; the preservation of the health and safety of the crew of any sanctioned vessel; emergency repairs of any sanctioned vessel; or environmental mitigation or protection activities related to any sanctioned vessel.
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Sanction Name
Non-SDN Palestinian Legislative Council Sanctions
SANCTIONS
First Imposed
Last updated
Targets
Trade Restrictions:
US financial institutions are required to reject transactions with members of the Palestinian Legislative Council who were elected on the party slate of Hamas, or any other Foreign Terrorist Organization, Specially Designated Terrorist, or Specially Designated Global Terrorist, provided that any such individuals are not named on OFAC’s list of Specially Designated Nationals and Blocked Persons (SDN List).
US sanctions programmes targeting cyber-related activities were first instituted by executive order in 2015 and strengthened by additional measures the following year.
On 16th May 2022, the EU extended its cyber sanctions regime for three years until 18th May 2025.
Sanction Name
Restrictive Measures Against Cyber-Attacks Threatening The Union or its Member States
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze and Travel Ban:
• Individuals and/or entities responsible for cyber-attacks or attempted cyber-attacks, as well as those involved in or offering financial, technical or material support for these attacks and those who assist, encourage, facilitate or are associated with them.
On 16th September 2024, OFAC designated five individuals and one entity associated with the Intellexa Consortium for their role in developing, operating, and distributing commercial spyware technology that presents a significant threat to the national security of the United States.
On 26th September 2024, the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order that identifies PM2BTC—a Russian virtual currency exchanger associated with Russian individual Sergey Sergeevich Ivanov (Ivanov)—as being of “primary money laundering concern” in connection with Russian illicit finance. Concurrently, OFAC sanctioned Ivanov and Cryptex—a virtual currency exchange registered in St. Vincent and the Grenadines and operating in Russia.
On 1st October 2024, OFAC sanctioned seven individuals and two entities associated with the Russia-based cybercriminal group Evil Corp, in a tri-lateral action with the United Kingdom’s Foreign, Commonwealth & Development Office (FCDO) and Australia’s Department of Foreign Affairs and Trade (DFAT).
Sanction Name
Specially Designated National of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities
First Imposed
Last updated
Targets
Specially Designated National:
• Individuals involved in cyber-enabled activities likely to contribute to a significant threat to US national security, foreign policy, economic health or financial stability. This includes the theft of trade secrets, personal identifiers, or financial information and those who benefit from such theft.
Exemptions
1. On 2nd February 2017 OFAC issued a general licence authorising transactions with Russia’s FSB to a value of under $5,000, provided that any transfer of goods or technology subject to Export Administration Regulations is licensed by the Department of Commerce.
2. On March 2nd 2021 OFAC issued General License 1B permitting certain transactions with the FSB for administrative reasons, as long as said transactions do not exceed $5,000 per calendar year.
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The US-programme on foreign election interference was precipitated by allegations that Russia sought to manipulate the result of the country’s 2016 Presidential election, which saw Donald Trump secure the office.
On 27th September 2024, OFAC designated seven individuals as part of a coordinated U.S. government response to Iran’s operations that sought to influence or interfere in the 2024 and 2020 presidential elections.
Sanction Name
Sanctions in the Event of Foreign Interference in a United States Election
First Imposed
Last updated
Targets
Specially Designated National:
• Any foreign person determined by the Secretary of the Treasury in consultation with the Secretary of State, the Attorney General and the Security of Homeland Security to have directly or indirectly engaged in foreign interference in a US election. Those deemed to have provided financial assistance or technological support for above persons are also sanctioned.
Since 2012 the US has published a list of foreign individuals and entities determined to have violated, attempted to violate, conspired to violate, or caused violations of US sanctions on Syria or Iran.
Sanction Name
Foreign Sanctions Evaders List
First Imposed
Last updated
Targets
Trade Restrictions:
• Transactions by US persons or within the US involving individuals and entities on the Foreign Sanctions Evaders list are prohibited.
In December 2020 the EU introduced its new Global Human Rights sanctions programme to target state and non-state actors guilty of human rights abuses.
On 4th December 2023 the European Council prolonged its Global Human Rights Sanctions Regime for three years until 8th December 2026.
Sanction Name
Global Human Rights Sanctions
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze and Travel Ban
• Any individuals, entities or bodies responsible for, involved in or associated with serious human rights violations and abuses worldwide, no matter where they occurred. It applies to acts such as genocide, crimes against humanity and other serious human rights violations or abuses. Other human rights violations or abuses can also fall under the scope of this sanctions regime, if they are widespread, systematic or otherwise of serious concern as regards the objectives of the EU common foreign and security policy.
The Global Magnitsky act, signed into law in 2016 by then US-President Donald Trump, extends the principles of the Magnitsky sanctions programme to all global actors.
On 20th December 2023 the US extended Executive Order 13818 with respect to human rights abusers and corrupt players for a further year until December 2024.
On 12th September 2024, OFAC sanctioned Cambodian businessman Ly Yong Phat (Ly), his conglomerate L.Y.P. Group Co., LTD (L.Y.P. Group), and O‑Smach Resort for their role in serious human rights abuse related to the treatment of trafficked workers subjected to forced labour in online scam centres. OFAC also designated Cambodia-based Garden City Hotel, Koh Kong Resort, and Phnom Penh Hotel for being owned or controlled by Ly.
On 16th September 2024, OFAC sanctioned four individuals who have undermined fundamental freedoms, including freedom of expression, in Georgia. Specifically, the Department of the Treasury sanctioned two Georgian government officials associated with brutal crackdowns on peaceful protestors and political opponents, and two private Georgian citizens that are responsible for or complicit in, or have directly or indirectly engaged in violently suppressing the exercise of the freedom of peaceful assembly of Georgians engaged in the democratic process and peaceful expression.
On 25th September 2024, OFAC sanctioned former member of Haiti’s parliament, Prophane Victor, for his role in forming, supporting, and arming gangs and their members that have committed serious human rights abuse in Haiti. OFAC also designated Luckson Elan, the current leader of the Gran Grif gang, for his involvement in serious human rights abuse related to gang activity in Haiti’s Artibonite department.
Sanction Name
Specially Designated Nationals on Persons Involved in Serious Human Rights Abuse or Corruption
First Imposed
Last updated
Targets
Specially Designated National:
• Individuals determined to be responsible for or complicit in, or to have directly or indirectly engaged in, certain human rights abuses or corrupt acts anywhere in the world.
• On 20th December 2017 an Executive Order was issued by then-President Trump, declaring a national emergency with respect to serious human rights abuses and corruption globally, and implementing the provisions of the Global Magnitsky Human Rights Accountability Act, signed into law on 23rd December 2016. The sanctions, effective from 21st December 2017, comprise financial sanctions and visa restrictions on persons deemed to be corrupt or accountable for human rights abuses.
Exemptions
1. General License 5 authorises certain transactions relating to Frigorifico Chajha SAE, and General License 6 authorises the wind down of transactions involving Bebidas USA Inc, Tabacos USA Inc, Frigorifico Chajha SAE, Dominica Acquisition SA, or certain blocked entities owned by Horacio Manuel Cartes Jara.
2. General Licence 7,authorises certain transactions involving Tabacalera del Este SA or Tabacos USA Inc pursuant to the Tobacco Master Settlement Agreement.
3. General License 8 authorises transactions involving any entity
that is blocked solely due to a property interest of Ly Yong Phat (Ly) or L.Y.P. Group Co., LTD (L.Y.P. Group) or any entity in which Ly or L.Y.P. Group owns, directly or indirectly, a 50 percent or greater interest.
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On 19th July 2022 OFAC introduced a new sanctions programme to bolster efforts to bring hostages and wrongfully detained US nationals home.
Sanction Name
Bolstering Efforts To Bring Hostages and Wrongfully Detained United States Nationals Home
First Imposed
Last updated
Targets
Asset Freeze and Travel Ban
• Any individuals, entities or bodies found to be responsible for or complicit in, to have directly or indirectly engaged in, or to be responsible for ordering, controlling, or otherwise directing, the hostage-taking of a United States national or the wrongful detention of a United States national abroad.
Magnitsky sanctions were imposed by the US in 2012 specifically targeting officials involved in the death of Russian accountant Sergei Magnitsky. Magnitsky died in 2009 while being detained in relation to an investigation by Russian law enforcement into the alleged theft of state assets by brokerage firm Hermitage Capital. He is alleged to have been tortured while in detention and the investigation itself is alleged to have been politically motivated.
Sanction Name
Magnitsky Rule Of Law Accountability Act Of 2012
First Imposed
Last updated
Targets
Specially Designated National:
• Russian officials determined to be responsible for Magnitsky’s death in custody.
• On 21st December 2017 OFAC added regulations to implement certain provisions of the Sergei Magnitsky Rule of Law Accountability Act of 2012. These included prohibited transactions involving blocked property; effect of transfers violating such provisions; the holding of funds in interest-bearing accounts, as well as those used for investment and re-investment; expenses of maintaining blocked physical property and liquidation of such property; evasions, attempts, causing violations and conspiracies; and exempt transactions.
Non-proliferation sanctions are operated by the US and the EU, targeting users and developers of chemical, biological and nuclear weapons.
On 14th October 2024, the EU extended its chemical weapons sanctions regime for one year until 16th October 2025.
Sanction Name
Restrictive Measures Against The Proliferation And Use Of Chemical Weapons
First Imposed
Last updated
Targets
Asset Freeze and Travel Ban
• Any individuals or entities responsible for the development and use of chemical weapons as well as those who provide financial, technical or material support for such activities and those who assist or who are associated with them.
Exemptions
1. Travel ban exemptions can be granted on a case-by-case basis on humanitarian grounds, for the attendance of intergovernmental meetings or for the fulfilment of judicial processes.
Sanction Name
Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters
SANCTIONS
First Imposed
Last updated
Targets
Specially Designated National:
• Any individuals found to be involved in the proliferation of material or knowledge relating to the construction of weapons of mass destruction and their wider support networks.
Exemptions
1. Under five General Licences, OFAC authorises certain transactions related to the arrest, detention and judicial sale of six specific vessels on its SDN list.
2. On 30th September 2020 OFAC issued amendments to the programme entitled Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters.
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OFAC and SECO both operate sanctions programmes in support of the Kimberley Process, which seeks to eliminate blood diamonds from the global market.
Sanction Name
Rough Diamond Trade Restrictions
First Imposed
Last updated
Targets
Trade Restrictions:
• The importation, export and storage of rough diamonds requires a tamper-proof certificate. Trade in rough diamonds is allowed only with countries participating in the Kimberly Process.
Sanction Name
Rough Diamonds Control Regulations
SANCTIONS
First Imposed
Last updated
Targets
Trade Restrictions:
• Prohibits the importation into and export from the US of any rough diamonds not controlled through the Kimberley Process.
OFAC operates sanctions against international criminal groups deemed to threaten the country’s national security.
Sanction Name
Specially Designated Nationals of Transnational Criminal Organizations
First Imposed
Last updated
Targets
Specially Designated National:
• Foreign entities determined to constitute significant transnational criminal organisations or to have materially assisted such organisations.
