Can secondary sanctions affect me even if I am not personally designated?

Yes, secondary sanctions — primarily a US tool — target non-US persons for conducting otherwise lawful business with designated parties. Under programs like CAATSA and Iran secondary sanctions, foreign companies and individuals risk being cut off from the US financial system, losing correspondent banking relationships, or facing their own designation for ‘significant transactions’ with sanctioned entities. Thresholds for triggering secondary exposure are often undefined, creating compliance uncertainty. Risk assessment requires analysing transaction volume, knowledge of counterparty status, and sector-specific guidance from OFAC, particularly regarding Russia and Iran-related dealings.