Secondary Sanctions and Extraterritorial Reach: Risks for Non-US Companies

Introduction

US secondary sanctions represent one of the most challengingand controversial aspects of the global sanctions landscape. Unlike primarysanctions, which apply to US persons and entities, secondary sanctions targetnon-US persons who engage in certain transactions with sanctioned countries orparties — even when no US nexus is present. This creates significant compliancerisk for banks, trading companies, and other organisations outside the UnitedStates. This advanced course provides a detailed analysis of US secondarysanctions, their extraterritorial reach, and the practical strategies non-US companiescan use to manage their exposure.

Who ThisCourse Is For

This course is designed for senior compliance, legal, and riskprofessionals at non-US financial institutions, trading companies, energyfirms, and technology companies that face exposure to US secondary sanctions.Participants should have a solid understanding of the US sanctions frameworkbefore attending.

WhatYou'll Learn

•      The legal basis for US secondary sanctions and how theydiffer from primary sanctions

•      The Iran, Russia, North Korea, and Venezuela secondarysanctions frameworks

•      How CAATSA and OFAC's 50% rule interact with secondarysanctions exposure

•      The concept of 'significant transactions' and how OFACassesses materiality

•      The risk of correspondent banking restrictions andde-risking consequences

•      Strategies for assessing and mitigating secondarysanctions risk

•      Jurisdictional conflicts: EU and UK blockingregulations

CourseStructure

Format: Live onlinesession with Q&A, also available as on-demand recording

Duration: 2 hours

Level: Advanced

Assessment: Noformal assessment — attendance certificate issued on completion

Technical Requirements

This course is compatible with most operating systems andmodern web browsers. Live sessions are delivered via video conferencing.On-demand recordings are accessible via the course platform. A stable internetconnection is recommended. If you experience access issues, please contact yourorganisation's IT department or the course provider.

‍Course Content

1. Primary vs SecondarySanctions: The Legal Architecture

•      Primary sanctions: who is bound and why

•      Secondary sanctions: expanding reach to non-US persons

•      The legal basis: executive orders, CAATSA, IFCA, CISADA

•      Diplomatic controversy and the EU/UK response

2. Key Secondary SanctionsProgrammes

•      Iran: the JCPOA, snapback, and current secondary risk

•      Russia: CAATSA Section 231, 232, and 233 obligations

•      North Korea: CAATSA Title III and correspondent bankingrisks

•      Venezuela: sectoral sanctions and petroleum sectorexposure

3. Assessing Exposure forNon-US Entities

•      The 'significant transaction' standard: factors OFACconsiders

•      Dollar-clearing, US technology, and US goods asexposure vectors

•      Correspondent banking: the systemic risk of US dollaraccess

•      Mapping secondary sanctions risk across business lines

4. Blocking Regulations andJurisdictional Conflict

•      EU Blocking Regulation: Council Regulation (EC) 2271/96

•      UK Blocking Legislation under the Trade (Australia andNew Zealand) Act

•      Managing conflicting legal obligations in practice

•      Case example: a non-US bank caught between US and EUobligations

5. Risk Mitigation Strategies

•      Contractual protections and sanctions clauses

•      Due diligence on counterparties and transaction chains

•      Engagement with OFAC: guidance letters and generallicence reliance

•      De-risking decisions: when to exit a relationship ormarket

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