Who must comply with Office of Foreign Assets Control regulations in all circumstances?

OFAC regulations apply broadly to US persons, which include US citizens, permanent residents, entities organized under US law, and individuals located in the United States. These obligations apply regardless of where the US person is physically located.

Foreign companies, foreign financial institutions, or foreign persons are only obligated under OFAC regulations when a US nexus exists (e.g., US origin goods, US dollars, US-based transactions). US persons, however, must always comply.