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Do not resign, transfer company property, or assume your job is illegal based only on the word “restricted.” First identify the exact U.S. measure, the legal entity it names or reaches, the activity involved, and whether your own status matters. Then verify the current position through the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), obtain situation-specific legal advice, preserve employment records you are entitled to keep, and quietly prepare for a transition using only non-confidential information.
This guide focuses on U.S. sanctions administered by OFAC. Export controls, government-contracting exclusions, immigration restrictions, and other measures can produce different rules and are not resolved by the OFAC guidance discussed here.
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What “U.S. restrictions” can mean for a job
“Restricted” is not a single legal status. OFAC explains that sanctions programs differ in scope and can change frequently. Some measures broadly restrict transactions involving a country or territory. Others target named people, companies, industries, or types of activity. A restriction may block property and transactions, or impose narrower, non-blocking limits.
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| Restriction pattern | What the OFAC guidance establishes | Why the distinction matters to an employee |
|---|---|---|
| Broad jurisdiction-based sanctions | Some programs restrict transactions connected with a jurisdiction. | The rule may concern the location, transaction, or property rather than every employer operating under a familiar brand. |
| Targeted person or entity sanctions | Other programs name particular people or entities. | Your employer’s exact legal name and the transaction you perform may determine whether the rule is relevant. |
| Sector or activity restrictions | Some programs target sectors or specified activities instead of imposing a blanket prohibition. | A role handling a covered activity may require a different analysis from an unrelated role at the same corporate group. |
| Ownership-based blocking | Under OFAC’s 50 Percent Rule, an entity can be blocked when blocked persons own at least 50 percent of it in aggregate, even if the entity is not separately named. | A simple name search may not resolve the employer’s status; ownership and control records may need review. |
| Non-blocking list restrictions | OFAC maintains lists that can impose restrictions without treating the person or entity as fully blocked. | Being absent from the SDN List does not automatically mean every transaction is permitted. |
These categories come from OFAC FAQs 10 and 91. They are classification tools, not a determination of your employment rights.
Start with a fact file, not a guess
When an employer announces a government action, save the notice and build a dated record. Do not rely on a headline, a social-media post, or a parent company’s public statement. Record the precise language used and ask for clarification through an appropriate internal channel.
- Capture the measure. Write down whether the notice refers to sanctions, a blocked-property designation, an export-control action, a government-contracting restriction, litigation, or another measure. The OFAC framework in this article applies only to sanctions questions.
- Identify the legal entity. Record the employer’s full registered name, incorporation country, subsidiaries involved, and any parent or affiliate named in the notice. Do not assume that a trading name and a listed entity are interchangeable.
- Record the program, list, and date. Note the OFAC sanctions program, list entry, executive order, agency notice, or other authority cited. Keep the date because sanctions programs may change.
- Describe your work. List your employing entity, work location, citizenship or other status relevant to the advice you receive, reporting line, access to funds or property, and the transactions you personally approve or process.
- Separate facts from assumptions. Mark what is documented, what management has said, and what you have inferred. This prevents a speculative conclusion from becoming the basis for a resignation or transfer.
Check whether the employer is actually covered
Search the current OFAC resources
OFAC’s sanctions-list service is the starting point for checking names and identifiers. Use the exact legal name, alternate spellings, registration details, and known owners. OFAC says sanctions programs may change frequently, so a past search, an old compliance memo, or a cached database result is not a current determination.
A search result is evidence to investigate, not a complete answer. OFAC FAQ 91 explains that some blocked entities may not appear on the SDN List because they are blocked through ownership. Other lists can impose non-blocking restrictions. Preserve the search date, terms, and result so counsel or your compliance team can reproduce the check.
Apply the 50 Percent Rule carefully
OFAC’s 50 Percent Rule can treat an entity as blocked when one or more blocked persons own, directly or indirectly, at least 50 percent in aggregate. The threshold is an ownership calculation, not a general statement that a company is “connected” to a sanctioned person. Ownership percentages, intermediary companies, and the relevant program all matter.
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Do not try to solve a complex ownership chain from a press article. Ask the employer for the legal entity and ownership information that compliance is permitted to provide, and have qualified sanctions counsel analyze the chain. Do not download or retain internal ownership files unless you are authorized to do so.
Do not equate a parent, subsidiary, and employer
A global group can contain entities with different legal names and different sanctions exposure. A parent may be named while a subsidiary is not; the subsidiary may nevertheless be blocked under the ownership rule, or it may be subject to a narrower measure. Your contract, payroll entity, and the entity directing your work should be identified separately.
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What the most direct employee FAQ actually says
OFAC FAQ 568, published April 6, 2018, addresses a narrow question involving a U.S. person employed by or serving on the board of certain entities blocked in connection with specified Russia-related designations. OFAC’s answer states: Absent authorization from OFAC, your continued employment or board membership with such an entity is prohibited.
That sentence is important, but its limits are equally important. It does not establish that every employee of every restricted company must leave, and it does not answer what a non-U.S. person, an employee outside the United States, or a worker at an entity subject to a different program may do. It also does not decide wage, severance, benefits, immigration, or wrongful-termination questions.
If your facts closely resemble FAQ 568, treat continued work as a time-sensitive sanctions issue and obtain advice before performing further duties. If your facts differ, do not stretch the FAQ beyond its stated scenario; have counsel map the actual program and activity to your circumstances.
Handle severance and other exit steps cautiously
In the FAQ 568 scenario, OFAC says to review contemplated actions needed to sever ties against applicable regulations, authorizations, and public guidance. If an action appears prohibited, the FAQ directs the person to apply for a specific license and to contact OFAC when uncertain.
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“Severing ties” can involve more than submitting a resignation. It may include receiving final pay, exercising equity, returning equipment, transferring accounts, signing releases, winding down contracts, or communicating with a blocked entity. The legality of each step depends on the facts and the applicable authorization. Do not move money, property, or records to create a cleaner exit without advice.
OFAC FAQ 9 describes a 10-business-day period for reporting certain blocked property. That is a rule about covered blocked property and reporting, not a general deadline for quitting or a rule that automatically applies to wages or benefits. Ask counsel whether any property in your possession or control falls within that requirement.
Protect your career while the status is being reviewed
Preserve records you are legally entitled to keep
Keep personal copies of documents that belong to you or that you may lawfully retain, such as your employment agreement, pay statements, benefit elections, performance reviews, job descriptions, and records of earned leave. Store them securely and maintain their original dates.
Do not copy customer data, source code, trade secrets, export-controlled technical information, sanctions-screening files, internal investigations, account credentials, or blocked property. Do not forward work email to a personal account merely to create a record. If you need evidence of compensation or job duties, request it through human resources or counsel.
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Update a resume without using confidential material
Describe your role using public, non-confidential information: broad responsibilities, industries served, tools you are authorized to name, and measurable outcomes that do not reveal protected data. Remove client names, unpublished financial results, restricted-country details, proprietary methods, and internal identifiers. Prepare a plain-text version for application systems and a longer version for conversations with recruiters.
Build references before a crisis forces a move
Identify former managers, peers, and professional contacts who can speak about your work without disclosing protected information. Ask whether they are comfortable serving as references and confirm the contact details you may share. A reference who cannot discuss the employer’s restricted operations can still verify your skills, reliability, and dates of employment.
Assess new opportunities discreetly
Review roles in organizations whose ownership, location, and business activities you can understand. During interviews, answer only what you are authorized to disclose. You can explain that you are evaluating a transition because of regulatory uncertainty without sharing nonpublic sanctions information. Ask prospective employers how they handle compliance questions and whether the role involves restricted jurisdictions, blocked persons, controlled technology, or government contracts.
Protect cash flow and benefits without assuming an outcome
The OFAC sources do not determine whether you are owed wages, bonus payments, severance, health coverage, retirement contributions, equity, or unused leave. Those questions depend on your contract, plan documents, applicable employment law, and the entities involved. A sanctions issue can make payment mechanics complicated, but it does not by itself answer what you are legally owed.
- Inventory what is outstanding: salary dates, commissions, bonuses, expense reimbursements, vested and unvested equity, retirement contributions, insurance coverage, and accrued leave.
- Read controlling documents: employment agreements, equity plans, benefit summaries, collective-bargaining terms, and any written change-in-control or severance policy.
- Build a conservative cash plan: separate essential expenses from discretionary spending and identify how long your liquid savings could cover necessities if payroll is delayed.
- Keep tax records: retain pay statements and year-end forms you are entitled to receive. Ask a tax professional about unusual payments, foreign accounts, or withheld amounts.
- Do not self-help with company funds: never offset an unpaid claim by taking equipment, customer money, securities, or other property.
If you work in the United States under a visa or work authorization, obtain immigration advice before changing employers, work locations, or duties. The sanctions FAQs do not establish immigration timelines or eligibility.
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Use a scenario-based decision framework
| What you know | Safer next step | What not to assume |
|---|---|---|
| A notice names a specific blocked entity and you are a U.S. person working for that entity. | Compare the facts with OFAC FAQ 568, pause potentially covered activity as advised by counsel, and ask OFAC about authorization if necessary. | Do not assume every employee, affiliate, or country is covered in the same way. |
| The employer is absent from the SDN List but ownership is unclear. | Check ownership and other OFAC lists; obtain a documented compliance analysis. | Absence from the SDN List does not prove that no restriction applies. |
| The announcement refers only to a broad jurisdiction program. | Identify the transaction, property, location, and activity that may be restricted. | Do not treat a jurisdiction measure as an automatic employment ban. |
| The action is an export-control or government-contracting measure rather than an OFAC sanction. | Obtain advice under the applicable agency’s rules and your employment law. | Do not use an OFAC FAQ as a substitute for a different regulatory analysis. |
| You have no verified designation and only media reports. | Preserve the report, request the legal entity and program involved, and avoid spreading unverified claims. | Do not resign, transfer property, or disclose confidential information solely because of a headline. |
Coordinate the right sources of help
Sanctions guidance
OFAC provides sanctions-list tools, license-application information, reporting resources, delisting information, and a compliance hotline. Use those official channels for questions about the scope of an OFAC program, a potential license, reporting, or whether a contemplated transaction is authorized. Keep a record of what you asked and the response you received.
Employment counsel
A lawyer who handles employment and sanctions matters can analyze termination, pay, benefits, severance, confidentiality, retaliation, and contract issues alongside the sanctions question. Tell counsel your work location, citizenship or status relevant to the advice, employing entity, job duties, and every written notice you received.
Benefits, tax, and immigration professionals
Use a benefits adviser for health and retirement coverage, a tax professional for unusual compensation or withholding, and immigration counsel for visa-related changes. Their analyses address questions the OFAC FAQs do not.
Common mistakes that can damage both compliance and employability
- Making a list search the entire analysis: a name match or non-match does not resolve ownership or non-blocking restrictions.
- Assuming the brand is the legal entity: payroll, contracting, and ownership entities may differ.
- Continuing sensitive work to appear helpful: routine activity can still involve a restricted transaction; obtain instructions in writing.
- Taking company data “for your records”: personal career protection never authorizes copying confidential or controlled material.
- Announcing an accusation publicly: public posts can disclose confidential information and make future employment harder.
- Signing a release under pressure: have counsel review severance, equity, benefits, and confidentiality terms before signing.
- Assuming a license is automatic: a specific license must be applied for and cannot be presumed while an application is pending.
A practical 30-day career-protection plan
Days 1–3: stabilize the facts
- Save the employer’s notice and your personal employment documents in a lawful, secure location.
- Write the full legal entity name, program or agency cited, date, and your role.
- Do not transfer funds, property, or restricted information while you seek instructions.
- Ask whether the employer has a written compliance directive and who is authorized to answer employee questions.
Days 4–10: verify and obtain advice
- Check current OFAC resources using the legal name and known ownership information.
- Ask qualified sanctions counsel to evaluate the program, entity, ownership, your status, and your activities.
- If the matter resembles FAQ 568, ask specifically about continued employment, board service, compensation, and each proposed severance step.
- Contact OFAC through its official channels when the scope, authorization, or reporting requirement remains uncertain.
Days 11–30: prepare options
- Update your resume and professional profile with non-confidential descriptions.
- Contact references and begin discreet networking.
- Model essential expenses under several payroll and severance scenarios.
- Review benefit-continuation, tax, and immigration consequences with the relevant professionals.
- Keep a dated log of instructions, applications, payments, and decisions.
Bottom line
Your safest career strategy is a two-track response: establish exactly what U.S. restriction applies, while preparing a lawful professional transition that does not use confidential information or move potentially blocked property. OFAC’s employee FAQ gives a strong warning for its specific U.S.-person and Russia-related blocked-entity scenario, but it is not a universal employment rule. Verify the current status, obtain sanctions and employment advice, and make each work, payment, and severance decision from the documented facts.
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