Yes, the rules still apply. In the US, the UK, Australia and New Zealand, sanctions law covers every business in the country. None of the four has an exemption for businesses that only buy and sell at home. What changes for a domestic business is the amount of checking that makes sense.
This guide gives the short answer for each country, shows where foreign exposure hides in a local business, and sets out a minimum check that fits.
The short answer by country
| Country | Does the law apply to a domestic business? | Is liability strict? | A proportionate minimum |
|---|---|---|---|
| United States | Yes. OFAC says "All U.S. persons must comply with OFAC sanctions." | Yes, for civil penalties | Check OFAC's lists for new contacts. Recheck on list changes. Keep records for 10 years. |
| United Kingdom | Yes. UK financial sanctions apply to all persons in the UK. | Yes, for civil penalties since 15 June 2022 | Check the UK Sanctions List for new contacts. Recheck on list changes. Keep records. |
| Australia | Yes. The laws cover activities in Australia. | Yes, for companies, with a reasonable precautions defence | Check DFAT's Consolidated List. Keep records that prove your precautions. |
| New Zealand | Yes. The Russia sanctions apply to everyone in New Zealand. | Penalties are set by the Russia Sanctions Act 2022 | Check the Russia Sanctions Register and UN listings. Keep records. |
US businesses can read more in do small businesses need OFAC screening? The sections below cover what a domestic business is actually exposed to.
Where foreign exposure hides in a local business
Most businesses that "only trade at home" have some foreign contact without thinking of it that way.
Overseas suppliers and subscriptions
Software, design work, components, stock from an online wholesaler, a freelancer on a marketplace. Each one is a vendor you pay. Some are abroad, and some are local resellers of foreign companies. Sort your vendor list in QuickBooks Online or Xero by country to see how many are abroad.
Online customers
A website that takes card payments can take them from anywhere. A customer with a local delivery address can still be a listed person or a company owned by one.
Local companies with foreign owners
A company registered down the road can be owned by someone abroad. OFAC treats a company 50% or more owned by blocked persons as blocked itself. The UK, EU and Australia have ownership and control rules of their own. A local name tells you nothing about who owns it.
Payments in other currencies
A customer who pays in US dollars, or a supplier who invoices in euros, brings in the banks of that currency. Banks screen those payments against their own country's lists. A UK business paid in dollars can have a payment held because of a US list. Our guide to OFAC for non-US companies explains why.
Sanctioned people and companies with local addresses
Sanctions lists are not only about foreign countries. We counted local addresses in the official files:
- OFAC SDN list (US): in OFAC's address file downloaded on 17 October 2026, 74 SDN entries had at least one United States address. 186 had a United Kingdom address and 6 had an Australian address.
- UK Sanctions List: in the file dated 16 October 2026, 47 of 6,408 designations had a UK address.
Those numbers are small next to the full lists. They show that "all my customers are local" does not mean "none of my customers can be listed." The lists name people and companies, not only countries.
What regulators expect from a lower-risk business
All four regimes expect effort that matches your risk.
- US: OFAC's compliance framework says a program "will vary depending on a variety of factors," including the company's size and sophistication, products and services, customers and geographic locations. It also says OFAC regulations "do not require a formal SCP." Whether you had a risk-based program at the time is one of the factors OFAC weighs if something goes wrong.
- UK: since 15 June 2022, OFSI does not have to prove you knew about a breach to impose a civil penalty. Its enforcement guidance still looks at what you did. For example, OFSI "will consider appropriate due diligence conducted on the ownership and control of an entity to be a mitigating factor" where you reached a reasonable conclusion in good faith.
- Australia: DFAT says sanctions offences are strict liability for companies. Section 16(7) of the Autonomous Sanctions Act 2011 gives a defence if the company "took reasonable precautions, and exercised due diligence." The company must prove it.
- New Zealand: MFAT says the Russia sanctions apply to "All individuals in New Zealand regardless of their nationality or resident status" and to all New Zealand businesses. Our Russia Sanctions Register guide covers the reporting duties.
In each country, a dated record of what you checked is how you show what you did.
The minimum setup for a domestic business
Four habits cover it.
- Check each new vendor and customer against your own country's list when you add them to your accounting system. Add OFAC if you deal in US dollars or with US companies.
- Recheck existing contacts when the lists change, or on a fixed schedule you can explain. The lists change often.
- Ask new foreign suppliers who owns them. Screen the owners too.
- Keep a dated record of each check: the name, the date, the list and the result. Write down why you cleared any near-match.
The manual process is in our guides for QuickBooks Online and Xero. For a single company, follow how to check if a company is sanctioned. For a fuller program, see sanctions compliance for small businesses.
Sanctions Verified, opening to QuickBooks Online and Xero users, checks every vendor and customer against the US, UK, EU, UN, Australian and New Zealand lists, rechecks them when the lists change, and keeps a dated certificate of each check. You can check one name now with the free check.
When a domestic business should do more
Move to a fuller process if any of these become true:
- you start selling or shipping abroad
- you take on foreign suppliers for goods you resell
- you get paid in foreign currencies regularly
- a bank, auditor or large customer asks how you screen
- you join a regulated sector, such as accounting, real estate or high-value dealing, where your regulator sets its own checks
At that point, the lists you screen and how often you screen should change. The sanctions compliance guide walks through the next step.
