OFAC Sanctions Resources and Recent Actions
Below we have provided, for your convenience, a list of the current economic sanctions programs enforced by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). They are divided into two broad categories:
New information available on the changes in the United States’ policy regarding Cuba.
Sanctions By Country:
Latest action taken: OFAC Removes Three Balkans Designations From the SDN List (February 7, 2014).
Overview of Balkans Sanctions:
OFAC initially implemented the Balkans-Related Sanctions Program pursuant to Executive Order 13219, which was issued by President George W. Bush on June 27, 2001. This sanctions program designated individuals and entities determined—by the Secretary of the Treasury in consultation with the Secretary of State—to be involved in extremist violence which took place in “the former Yugoslav Republic of Macedonia, in southern Serbia, the Federal Republic of Yugoslavia, and elsewhere in the Western Balkans region” beginning in 1999.
Although President George W. Bush terminated the Balkans-related national emergency in 2003 (Exec. Order 13304), a number of Balkans-related designations remained on—and were later added to—the SDN List.
Latest action taken: OFAC Designated Four Belarus-Related Entities and Added them to the SDN List (August 11, 2011).
Overview of Belarus Sanctions:
Pursuant to Executive Order 13405, issued by President George W. Bush on June 19, 2006, OFAC implemented sanctions against individuals and entities determined—by the Secretary of the Treasury in consultation with the Secretary of State—to “be responsible for, or to have participated in” activity that has undermined democratic processes, human rights abuses related to political oppression, or public corruption in Belarus. 31 CFR Part 548.
Latest action taken: OFAC Designated One Burma-Related Individual: A Lower House Member of Parliament (October 31, 2014)
OFAC amended and reissued in their entirety the Burmese Sanctions Regulations to implement Executive Order 13448, Executive Order 13464, Executive Order 13619, and Executive Order 13651 (June 30, 2014). The regulatory update was announced in the Federal Register here (pdf). The reissued Burmese Sanctions Regulations, 31 C.F.R. Part 537 can be accessed here.
Overview of Burma Sanctions:
Pursuant to Executive Order 13047, issued by President Bill Clinton in May 1997, OFAC implemented sanctions against the Government of Burma for large-scale repression of democratic opposition in Burma. For the next 15 years, a number of country-based and smart sanctions were promulgated against the Government of Burma and designated persons for human rights abuses and democratic oppression.
In July, 2012, in response to substantial democratic reforms in Burma, President Barack Obama and OFAC began to ease certain sanctions on Burma. On August 6, 2013, President Barack Obama issued Executive Order 13651, which lifted parts of the country-based sanctions on Burma. The designations against individuals and entities, however, remain in place. (OFAC Overview of Burma Sanctions) (Updated OFAC Burmese Sanctions FAQ).
Central African Republic
Latest action taken: OFAC Issued Final Rule Adding Regulations Implementing Executive Order 13667 to to 31 CFR part 553 (July 7, 2014)
President Barack Obama issued Executive Order 13667 on May 12, 2014 providing criteria for the designation of persons in the Central African Republic, in addition to a list of five individuals. The criteria for designation includes:
- Engaging in activity threatening the democracy, peace, stability, or security of the CAF,
- Targeting of civilians, particularly women and children, for acts of violence or displacement,
- Using or recruiting child soldiers in armed groups,
- Obstructing humanitarian missions or aid, and
- Supporting any persons who meet any of the criteria above.
OFAC has not published Central African Republic Sanctions Regulations, but it has already designated at least five persons and added them to the SDN List.
Cote d’Ivoire (Ivory Coast)-Related
Latest action taken: OFAC Designated Five Cove d’Ivoire-related Individuals and Added them to the SDN LIST (January 6, 2011).
President George W. Bush issued Executive Order 13396 on February 7, 2006, “to address the situation in or in relation to Côte d’Ivoire that resulted in the massacre of a large numbers of civilians, widespread human rights abuses, significant political violence and unrest, and attacks against international peacekeeping forces leading to fatalities.” For the full text of the executive order, please see the OFAC Cote d’Ivoire Sanctions Program Informational Brochure (pdf). The Cote d’Ivoire sanctions are list-based sanctions targeting individuals and entities rather than a country-based sanctions program. 31 CFR Part 543 (pdf).
President Obama recently announced that the United States will establish diplomatic ties with Cuba and establish an embassy in Havana, Cuba. Here is the Charting a New Course on Cuba Fact Sheet from the White House. In the upcoming weeks, OFAC will implement the White House’s policy changes. An OFAC Sanctions Attorney speaks on these changes and how they will impact OFAC ‘s Cuba Sanctions Program here. Check back for more information as OFAC implements these changes.
The oldest sanctions program administered by OFAC, the Cuban Assets Control Regulations (31 CFR Part 515) constitute the broadest and strictest country-based sanctions program in effect. The sanctions began in 1963, and continue to this day. For more detailed information, visit our Cuba Sanctions page or visit OFAC’s resource page. With President Obama’s latest announcement, however, the sanctions will be undergoing major changes in the next several weeks.
Democratic Republic of Congo-Related (DRC)
Latest action taken: President Obama Issued An Executive Order Taking Additional Steps to Address the National Emergency with Respect to the Conflict in the DRC (July 8, 2014) (Executive Order pdf here)
OFAC’s DRC-Related Sanctions began when President George W. Bush issued Executive Order 13413 (pdf) on October 27, 2006. The sanctions were implemented to address “the widespread violence and atrocities in the DRC that threatened regional stability.” OFAC Overview of DRC Sanctions Program (pdf). In the face of efforts for the demobilization, repatriation, and resettlement of armed groups in the DRC, the sanctions target armed groups (and particularly their political and military leaders), foreign and Congolese, that impede these efforts. In addition, OFAC’s DRC-related sanctions specifically target armed groups that recruit and use children in armed conflict (child soldiers). The sanctions also target armed groups that target children for “killing and maiming, sexual violence, abduction, and forced displacement.” 31 CFR Part 547 (pdf); see also Exec. Order 13413 Section 1(a). Lastly, the sanctions prohibit the immigration of and contributions to these armed groups and individuals who meet the criteria described above.
Latest action taken: OFAC Published Key Documents to Continue Implementation of the United States’ Commitment Under the the Joint Plan of Action (November 25, 2014). This includes:
- Guidance Relation to Provision of Certain Temporary Sanctions Relief In Order to Implement the Joint Plan of Action Reached on 11/24/2013 Between the P5+1 and The Islamic Republic of Iran, as Extended through June 30, 2015 (pdf),
- FAQ Relating to Extension of Temporary Sanctions Relief through June 30, 2015 (pdf), and
- Second Amended Statement of Licensing Policy on Activities Related to the Safety of Iranian Civil Aviation Industry (pdf)
Other notable recent actions:
OFAC Made Adjustments to Designations on Several Entities and Vessels, Some of Which Are Subject to Secondary Sanctions (July 29, 2014). The threat of secondary sanctions apply to these entities and vessels, meaning any foreign financial institution or person that facilitates significant transactions or provides material support to these entities or vessels may have their access to the U.S. financial system severed or their property and interests in property under U.S. jurisdiction blocked.
Iran is the subject of broad country-based sanctions, in addition to list-based smart sanctions. Furthermore, secondary sanctions also target certain non-U.S. individuals and entities that do significant amounts of business with Iran. For more information, please visit our Iran page here.
Latest action taken: OFAC Published an update to Questions Relating to the Payments or the Facilitation of Payments to Iranian civil Aviation Authorities for Overflights of Iran or Emergency Landing in Iran (November 4, 2014) (Updated Question and Answer 417)
President Barack Obama Issued Executive Order 13668, Ending Immunities Granted to the Development Fund for Iraq and Certain Other Iraqi Property and Interests Pursuant to Executive Order 13303, as Amended (May 27, 2014).
Iraq has been the subject of numerous sanctions since its invasion of Kuwait in August of 1990. The sanctions have changed as the situation in Iraq and the U.S. relationship with Iraq has shifted. In September of 2010, OFAC published a final rule in the Federal Register terminating the national emergency declared with respect to Iraq in Executive Order 12722 by removing the Iraqi Sanctions Regulations from the Code of Federal Register. New regulations were thereafter implemented. These regulations, called the Iraq Stabilization and Insurgency Sanctions Regulations (ISISR), implement list-based sanctions against individuals and entities associated with former Saddam Hussein’s regime. They also target specific individuals and entities that have committed acts of violence “threatening the peace or stability of Iraq or the Government of Iraq or undermining efforts to promote economic reconstruction and political reform in Iraq or to provide humanitarian assistance to the Iraqi people.” OFAC’s Overview of ISISR (pdf); see also 31 CFR Part 576.
Latest action taken: OFAC issued the Lebanon Sanctions Regulations (31 CFR Part 589) to Implement Executive Order 13441 (July 30, 2010).
President George W. Bush issued Executive Order 13441 (pdf) on August 1, 2007, declaring a national emergency because of “the actions of certain persons to undermine Lebanon’s legitimate and democratically elected government or democratic institutions.” Exec. Order 13441. This includes actions taken to advance the “deliberate breakdown of the rule of law in Lebanon,” particularly to facilitate Syria’s control over and infringement on Lebanon’s sovereignty. Exec. Order 13441. Individuals and entities involved in these acts, particularly through violence and intimidation, are targeted by OFAC’s list-based sanctions. This also includes a prohibition on immigration of and contributions to these persons, their family, or entities owned or controlled by such persons. Exec. Order 13441 has been implemented by OFAC in the Lebanon Sanctions Regulations. 31 CFR Part 589.
Former Liberian Regime of Charles Taylor
Latest action taken: OFAC Has Removed the Designations of 28 Liberia-related Individuals and Deleted Them From the SDN List (April 2, 2013).
President George W. Bush issued Executive Order 13348 (pdf) in July of 2004, “Blocking Property of Certain Persons and Prohibiting the Importation of Certain Goods from Liberia.” The executive order and subsequent sanctions regulations largely targeted members of former Liberian President Charles Taylor. See OFAC’s Overview of Sanctions Against The Former Liberian Regime of Charles Taylor (pdf). This was precipitated by the Former Liberian Regime of Charles Taylor’s actions impeding democratic and peaceful transition in government, including removing Liberian resources and funds from the nation and facilitating illegal arms trafficking contributing to armed conflict. 31 CFR Part 593.
Latest action taken: OFAC Removed One Libya-related Individual from the SDN List (September 11, 2014)
President Barack Obama issued Executive Order 13566 on February 25, 2011, targeting Colonel Muammar Qadhafi, aka Muammar al-Gaddafi, officials in his government, and his close associates for violent acts against his civilian population. OFAC implemented Exec. Order 13566 in the Libyan Sanctions Regulations (31 CFR Part 570). The Libyan sanctions are not country-based, but instead focus on individuals, entities, and groups that are closely related to Qadafi, his family, and his regime. These list-based sanctions also prohibit immigration of and contributions to the persons who meet the criteria set out in 31 CFR Part 570 and who have been designated by OFAC.
Latest action taken: OFAC Designated 12 Individuals Pursuant to the Magnitsky Sanctions, Added to the SDN List (May 20, 2014).
Unlike most of the OFAC sanctions programs, the Magnitsky Sanctions are the direct product of a statute rather than an executive order. Congress passed the Sergei Magnitsky Rule of Accountability Act of 2012 (pdf) on December 14, 2012, named after a Russian accountant and auditor who was investigating tax fraud in Russia before he was arrested and died in custody under suspicious circumstances. The list-based Magnitksy Sanctions target the individuals responsible for the death, abuse, and detention of Sergei Magnitsky, in addition to individuals responsible for other gross violations of human rights in the Russian Federation. Those individuals identified as meeting the criteria described above will be placed on the SDN List, and will be subject to the freezing of their assets under U.S. jurisdiction and prohibited immigration.
Latest action taken: OFAC Designated Two DPRK-Related Individuals and 15 DPRK-Related Vessels, Adding Them to the SDN List (July 30, 2014).
North Korea is one of five countries subject to broad country-based OFAC economic sanctions. President George W. Bush issued Executive Order 13466 (pdf) in June of 2006, targeting the nation of North Korea for threatening the national security and foreign policy of the U.S., particularly in relation to North Korea’s current programs and efforts in the proliferation of nuclear weapons. OFAC subsequently implemented Exec. Order 13551 and Exec. Order 13570 imposing further sanctions on North Korea and list-based sanctions on certain persons. These sanctions are now promulgated in the North Korea Sanctions Regulations (NKSR). 31 CFR Part 510. The NKSR generally prohibit transactions, exports, and imports with respect to North Korea and certain persons related to the government of North Korea.
Latest action taken: OFAC Designated Six Somalia-Related Individuals and Added Them to the SDN List (July 5, 2012).
President Barack Obama issued Executive Order 13536 (pdf) in April of 2010 to address “the deterioration of the security situation and the persistence of violence in Somalia,” with a particular focus on the acts of piracy and armed robbery off Somalia’s coast and violations of the United Nations arms embargo. Exec. Order 13536. OFAC implemented the Somalia Sanctions Regulations (31 CFR Part 551), list-based sanctions targeting individuals and entities threatening peace, security, and stability in Somalia, or who are otherwise obstructing the delivery of humanitarian aid, transferring or receiving arms in Somalia, or funding or contributing to such groups. The sanctions block property belonging to persons who meet the criteria above, in addition to prohibiting immigration of or contributions to such persons. See OFAC’s Overview of Somalia Sanctions Regulations (pdf).
Latest action taken: OFAC Issues Amended Sudan General License No. 1A and Published Frequently Asked Questions Regarding the Changes (August 11, 2014) (FAQ here)
Sudan has been the target of broad OFAC country-based sanctions since 1997, when President Bill Clinton issued Executive Order 13067 (pdf). Further list-based sanctions were implemented pursuant to Executive Order 13400 (pdf) (2006), targeting individuals and entities involved in the human rights abuses and atrocities in Sudan’s Darfur region. President George W. Bush also issued Executive Order 13412, which exempted the regional Government of Southern Sudan from the country-based sanctions against Sudan. These sanctions were implemented in the Sudanese Sanctions Regulations (31 CFR Part 538) and the Darfur Sanctions Regulations (31 CFR Part 546). More information on these various sanctions can be found in OFAC’s Overview of the Sudan Sanctions Program (pdf).
Latest action taken: OFAC Designated Two South Sudan-related Individuals, and Added them to the SDN List (September 18.2014)
On April 7, 2014, President Barack Obama issued Executive Order 13664 (pdf) to address “activities that threaten the peace, security, or stability of South Sudan and the surrounding region, including widespread violence and atrocities, human rights abuses, recruitment and use of child soldiers, attacks on peace-keepers, and obstruction of humanitarian aid.” Executive Order 13664. The list-based sanctions block property and prohibit immigration of or contribution to individuals and entities involved in activities described above, in addition to any targeting of women, children, or any civilians for violence, abduction, or displacement. This includes the leaders of groups, militias, or the Government involved in these acts, and anyone who has materially assisted or provided support for these persons. Because this executive order is so recent, OFAC has yet to implement these sanctions in regulations. However, this does not mean OFAC is not enforcing these sanctions. (OFAC South Sudan FAQ here).
Latest action taken: OFAC Designated a Five Syria-related Individuals and Six Syria-related Entities, adding them to the SDN List; OFAC Also Added Three Syria-related Individuals and Three Syria-related Entities to the Foreign Sanctions Evaders List; (December 17, 2014)
Syria is one of the five countries subject to OFAC’s broad country-based sanctions. In 2004, President George W. Bush issued Executive Order 13338 (pdf) to address the Government of Syria’s support of terrorism, occupation of Lebanon, proliferation of weapons of mass destruction, and attempts to undermine U.S. and international efforts to stabilize Iraq. Exec. Order 13338. In March of 2011, events in Syria resulted in subsequent Executive orders and sanctions to address armed conflict, human rights abuses, and atrocities occurring in Syria. The Syrian Sanctions Program is one of the most comprehensive implemented by OFAC. See OFAC’s Overview of the Syria Sanctions Program. The country-based and list-based sanctions are implemented in OFAC’s Syrian Sanctions Regulations. 31 CFR Part 542.
Latest action taken: President Obama Issued a New Ukraine-related Executive Order Regarding the Crimea Region; OFAC Issued the Ukraine-related General License 4; OFAC also Designated 17 Ukraine-related Individuals and Seven Ukraine-related Entities (December 19, 2014) (Executive Order pdf) (General License 4 pdf)
OFAC Published New Frequently Asked Questions Regarding Ukraine-related Sanctions (December 11, 2014) (FAQ here)
OFAC Published New Frequently Asked Questions Regarding Ukraine-related Sanctions (November 18, 2014) (FAQ here)
OFAC Pubilished the Ukraine-Related General License 3 (October 6, 2014) (pdf of General License 3)
OFAC Added Seven Ukraine-related Entities to the Sectoral Sanctions List, and issued Ukraine-related General License 1 and Ukraine-related General License 2 (Septemeber 12, 2014) (pdfs: General License 1; General License 2)
In response to ongoing situation in Ukraine, President Barack Obama issued three Executive Orders in March of 2014: Exec. Order 13660, Exec. Order 13661, and Exec. Order 13662 (all pdfs). These list-based sanctions target specific individuals listed in the Executive Order, in addition to other individuals and entities that are contributing to the destabilizing situation in Ukraine. Finally, the sanctions also target government officials of the Russian Federation, individuals involved in certain major parts of the Russian economy, and entities owned or controlled by these individuals. OFAC implemented these executive orders in the Ukraine-Related Sanctions Regulations (31 CFR Part 589) (pdf), which are currently incomplete because of the rapidly changing situation. More information is available at our Ukraine-Related Sanctions Program page. Recently, OFAC has issued further Sectoral Sanctions.
Latest action taken: OFAC Designated Three Yemen-related Individuals, Adding Them to the SDN List (November 10, 2014)
OFAC implemented the Sanctions Against Persons Threatening the Peace, Security, or Stability of Yemen pursuant to Executive Order 13611 (pdf), issued by President Barack Obama on May 16, 2012. Exec. Order 13611 was issued in response to “actions and policies of certain members of the Government of Yemen and others [threatening] Yemen’s peace, security, and stability. In particular, OFAC’s Yemen Sanctions Regulations (31 CFR 552) targets individuals and entities that have obstructed the peaceful transition of the Government of Yemen, in addition to persons who have materially assisted, funded, or supported those described above. This includes political and military leaders. These list-based sanctions block the property and money of designated persons under U.S. jurisdictions. Moreover, the sanctions prohibit immigration of and contributions to individuals and entities described above.
Latest action taken: OFAC Published the Final Rule in the Federal Register Amending the Zimbabwe Sanctions Regulations (July 10, 2014) (pdf of Federal Register here)
In March of 2003, President George W. Bush issued Executive Order 13288 (pdf), imposing sanctions on specific individuals and entities in Zimbabwe involved in activity undermining democratic institutions and processes in Zimbabwe. Ongoing political violence and intimidation, which continued to undermine democratic institutions and processes in Zimbabwe, prompted President George W. Bush to issue Exec. Order 13391 (pdf) and then Exec. Order 13469 (pdf). OFAC implemented these executive orders in OFAC’s Zimbabwe Sanctions Regulations (31 CFR Part 541). These sanctions broadened the scope of the sanctions to the family members of and persons providing assistance to the individuals listed in Exec. Order 13288. The sanctions block the property of those listed persons subject to U.S. jurisdiction and prohibit contributions to such OFAC-designated individuals and entities. For more information, see OFAC’s Overview of Zimbabwe Sanctions Program.
Sanctions by Law Enforcement Program:
Counter Narcotics Trafficking Sanctions
Latest action taken: OFAC Designated Ten Kingpin-related Individuals and 14 Kingpin-related Entities, Adding Them to the SDN List (November 19, 2014)
OFAC Designated Eight Kingpin-related Individuals, Adding Them to the SDN List (September 16, 2014)
OFAC economic sanctions were first implemented against narcotics traffickers in October of 1995, when President Bill Clinton issued Executive Order 12978 (pdf). Exec. Order 12978 targeted individuals and entities involved in Colombia-centered narcotics trafficking. However, in 1997, Congress passed the Foreign Narcotics Kingpin Designation Act (hereafter, “Kingpin Act”) to more effectively apply OFAC sanctions against foreign narcotics traffickers and their organizations. The Kingpin Act is an entirely independent source of legal authority to implement sanctions against narcotics traffickers. The sanctions target individuals and entities involved in foreign narcotics trafficking, and entities owned, controlled by, or acting on behalf of such persons.
OFAC’s sanctions block property belonging to such persons where it is or comes under U.S. jurisdiction. Furthermore, the sanctions prohibit transactions with sanctioned persons. OFAC implemented these executive orders and the Kingpin Act in the Narcotics Trafficking Sanctions Regulations (31 CFR Part 536), and in the Foreign Narcotics Kingpin Sanctions Regulations (31 CFR Part 598).
These list-based sanctions are heavily based on the use of the SDN List, effective enforcement mechanisms, and effective screening measures. More information is available at our Narcotics Trafficking Sanctions page, or in OFAC’s Overview of the Narcotics Sanctions Program (pdf).
Counter Terrorism Sanctions
Latest actions taken: OFAC Designated Two Terrorism-related Individuals and One Terrorism-related Entity, Adding Them to the SDN List (December 18, 2014)
OFAC Removed 17 Terrorism-related Individuals from the SDN List (November 26, 2014)
Since the attacks on September 11, 2001, OFAC has developed a comprehensive counter terrorism sanctions program that relies on the efficacy of list-based sanctions and measures like automated screening. Executive Order 13224 (pdf), issued by President George W. Bush, blocks the property of and prohibits transactions with individuals and entities that have committed, threaten to commit, or provide material assistance for terrorism. The definition of terrorism is examined further here.
OFAC has implemented the executive orders and statutes issuing terrorism-related sanctions in the Global Terrorism Sanctions Regulations (31 CFR Part 594), the Terrorism Sanctions Regulations (31 CFR Part 595), the Terrorism List Government Sanctions Programs (31 CFR Part 596), and the Foreign Terrorist Organizations Sanctions Regulations (31 CFR Part 597).
Non-Proliferation of Weapons of Mass Destruction (WMD) Sanctions
Latest action taken: OFAC Removed Three NPWMD-related Entities From the SDN List (October 16, 2014)
There are three WMD sanctions programs administered by OFAC. First, pursuant to Executive Order 13382 (pdf), which was issued in June of 2005, OFAC implemented list-based sanctions that target “persons engaged in proliferation activities and their support networks.” See OFAC’s Overview Non-Proliferation Sanctions (pdf). These sanctions initially targeted eight organizations in Iran, North Korea, and Syria, but the scope has been broadened to include other proliferators and their support networks. They were implemented in OFAC’s WMD Proliferators Sanctions Regulations (31 CFR Part 544).
Second, pursuant to Executive Order 12938 (pdf) (issued in 1994), OFAC implemented the WMD Trade Control Regulations (31 CFR Part 539) to target importation of certain materials, or from certain designated persons, into the United States.
Third, pursuant to Executive Order 13159 (pdf) (issued in 2000), OFAC implemented the Highly Enriched Uranium Assets Control Regulations (31 CFR Part 540), which targets a very specific set of assets and materials related to the extraction of uranium from nuclear devices in Russia.
Rough Diamond Trade Controls
Latest action taken: OFAC Amended the Rough Diamonds Control Regulations (31 CFR Part 592) to Add Requirements Designed to Enhance the Collection of Statistics Related to Importations and Exportations of Rough Diamonds (May 21, 2008).
In November of 2002, the U.S. and 47 other nations launched the Kimberley Process Certification Scheme for rough diamonds (KPCS), which prohibits importation of rough diamonds from non-participant nations. In April of 2003, Congress passed the Clean Diamond Trade Act to implement the KPCS. Pursuant to Executive Order 13312 (pdf) (signed 2003), OFAC implemented the Rough Diamonds Control Regulations (31 CFR Part 592).
These sanctions prohibit the U.S. importation and exportation of any rough diamonds not controlled by the KPCS. Thus, exports of rough diamonds must adhere to KPCS standards and practices. Furthermore, the import of rough diamonds from non-KPCS nations is prohibited.
Transnational Criminal Organizations (TCO)
Latest action taken: OFAC Designated Eleven TCO-Related Individuals and One TCO-Related Entity, Adding Them to the SDN List (July 2, 2014).
President Barack Obama issued Executive Order 13581 (pdf) July 25, 2011, in order to address the threats transnational criminal organizations have posed to the U.S. economy, foreign policy, and national security. OFAC implemented these sanctions in the Transnational Criminal Organizations Sanctions Regulations (31 CFR Part 590). These sanctions include a list of specific individuals and entities that are involved in, or materially assist, TCOs. It also permits the Secretary of the Treasury, in consultation with the Secretary of State, to designate additional TCOs, members, and supporters. See OFAC’s Overview of the TCO Sanctions Program.