Can Secondary Sanctions Affect Unlisted Persons? | FAQ
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Can secondary sanctions affect me even if I am not personally designated?

Yes. A person or company does not need to appear on a sanctions list to face secondary sanctions exposure. Under certain US programs, non-US parties may be targeted for knowingly conducting specified transactions or supporting sanctioned persons or sectors.

The risk depends on the applicable sanctions program, the nature and scale of the activity, awareness of the parties involved, and whether an exemption or authorisation applies.

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