Transnational Criminal Organizations
Country-Level and Policy-Level Programs. Certain of the sanctions programs are focused on individual countries (the “country-level programs”), while others target specific activities on a global basis such as terrorist and non-proliferation sanctions (the “policy-level programs”). Under a number of the country-level programs (such as Iran, Syria, N. Korea, Cuba and the Crimea region of Ukraine – the “comprehensive sanctions programs”) U.S. persons are prohibited from entering into effectively all business transactions with the targeted country, its government and its nationals, including the export and import of products, technologies and services, payments and investments, subject to exceptions described below.[5] For other country-level programs, such as Russia, Ukraine and Venezuela, certain business activities within the country are prohibited but others are permitted (the “partial sanctions programs”). For