Sanctions screening
Sanctions screening in Defense and Government Contracting sits at the intersection of two enforcement regimes: the U.S. Department of the Treasury's Office of Foreign Assets Control, which administers the SDN List and sector-specific sanctions programs, and the U.S. Department of State's Directorate of Defense Trade Controls, which controls what flows to whom under ITAR. Contractors holding federal awards are also subject to Federal Acquisition Regulation clause 52.209-6, which requires disclosure of covered telecommunications and affiliations with sanctioned entities. Compliance teams are currently re-mapping subcontractor and vendor chains against updated OFAC designation criteria following the 2024 expansion of Russia-related sanctions.
Watch
- OFAC SDN List updates affecting Russian defense-sector entities and their subsidiaries
- FAR 52.209-6 disclosure obligations when a subcontractor triggers a new designation
- DDTC policy shifts on re-export licensing to allied-nation defense partners
- Beneficial ownership verification requirements under FinCEN's Corporate Transparency Act rules for government contractors
Recent material activity in Defense & Government Contracting
Active monitoring in place across Defense & Government Contracting. Material developments related to sanctions screening will appear here as they are published.