Glossary
Secondary sanctions
Measures that target non-US persons for dealings with sanctioned parties, even outside US jurisdiction. They extend the practical reach of a regime well beyond its home territory.
A worked example and links to the primary regulators are added in Phase 2. For how this applies to a specific matter, a fixed-fee written position is the proportionate step.
Related terms
SDN vs sectoral sanctions The OFAC 50% Rule Ownership vs control (EU) EAR99 and ECCN