Disbursement Controls Resource · Reference Tables

State Department Sanctions & Debarment Reference

These designations are made under separate statutory authority from OFAC — the Immigration and Nationality Act, the Arms Export Control Act, and the Iran, North Korea, and Syria Nonproliferation Act, respectively. Several overlap with OFAC's SDN List in practice, but each carries its own legal basis, scope, and consequence.

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$1M

Maximum criminal fine per willful violation under the Arms Export Control Act

20 yrs

Maximum imprisonment for providing material support to a designated terrorist organization

3 yrs

Typical duration of an AECA debarment before reinstatement may be requested

Program / Item	What It Covers	Why AP Should Care
Designated Foreign Terrorist Organizations (FTO)	Groups formally designated by the Secretary of State under Section 219 of the Immigration and Nationality Act for engaging in, or retaining the capability and intent for, terrorism that threatens U.S. security.	A separate legal designation from OFAC's SDN/SDGT listing. Screen the FTO list by name even though most FTOs also end up blocked on the SDN list — providing material support to a listed group is itself a federal felony.
AECA Debarred Parties List (Directorate of Defense Trade Controls)	Individuals and entities convicted of (statutory debarment) or administratively found to have violated the Arms Export Control Act and ITAR, barring them from participating directly or indirectly in any defense-article export.	Narrowly scoped to ITAR-controlled defense trade. A vendor can be entirely clean on OFAC's SDN List and still be debarred here if defense articles, technical data, or defense services are involved.
Iran, North Korea, and Syria Nonproliferation Act List (INKSNA)	Foreign persons and entities sanctioned for transferring or acquiring WMD- or missile-related equipment and technology to or from Iran, North Korea, or Syria, reviewed and reported periodically by State's nonproliferation bureau.	Triggers a U.S. government procurement ban and other measures independent of any OFAC country sanctions program. Relevant for vendors with defense, aerospace, or dual-use technology exposure.

This reference is provided as an educational resource for accounts payable, treasury, and shared services professionals. It does not constitute legal, tax, or compliance advice. Figures and list contents change; verify against the official source before acting.