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Beware of Specially Designated Nationals when doing business overseas

I have a niche database business converting legacy FoxPro and Clipper applications to Windows and the cloud and get inquiries from all over the world. I’ve learned to pay careful attention to where the inquiry is from. The US Department of Treasury has a Specially Designated Nationals List of people worldwide that US citizens are not allowed to do business with. This includes any company they are connected to. Such bans can also apply to entire countries.

I just turned down an inquiry from a company based in Iran, after finding the following in a Treasury bulletin about Iran.

“In general, unless licensed by OFAC, goods, technology, or services may not be exported, reexported, sold or supplied, directly or indirectly, from the United States or by a U.S. person, wherever located, to Iran or the Government of Iran.”

Government regulations are frequently lengthy, confusing, and hard to understand. By contrast, the above one sentence is a model of clarity and rules out any business relationships with any entity in Iran.

A while back I received an inquiry from a Zimbabwe company. They were not on the SDN list but I called Treasury anyway. They said to ask the company if anyone connected with them was on the SDN list. I did so and never heard back. Thus, I assume their answer was yes.

Penalties for dealings with Specially Designated Nationals or banned countries are extremely severe. So, if you sometimes do business overseas and didn’t know about SDNs, now you do. Don’t go near them.

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