Peru OFAC sanctions
Peru is not subject to comprehensive sanctions administered by the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC). As of mid-2026, Peru is a US free-trade partner under the United States–Peru Trade Promotion Agreement and maintains normal commercial relations with the United States. This does not mean, however, that businesses and individuals with Peru-related transactions are free from OFAC compliance obligations. US persons and entities must still screen counterparties, beneficial owners, and transaction flows against OFAC’s Specially Designated Nationals and Blocked Persons List (the SDN List), as well as comply with sectoral sanctions that may apply to third-country actors operating in or through Peru. Peruvian financial institutions, exporters, and cross-border investors face parallel obligations under Peru’s own anti-money laundering framework, supervised by the Unidad de Inteligencia Financiera (UIF-Peru), and under Financial Action Task Force (FATF) standards to which Peru is subject through the Financial Action Task Force of Latin America (GAFILAT). Law Offices of SRIS, P.C. advises US and international clients on OFAC compliance as it intersects with Peruvian transactions, drawing on the firm’s US-licensed attorneys and its Of Counsel network in the region. For a consultation on your Peru-related OFAC compliance matter, reach the firm at (888) 437-7747.
What Peru OFAC Sanctions Compliance Covers
OFAC compliance for Peru-related transactions focuses primarily on the application of US sanctions laws to individuals, entities, vessels, and financial flows that may touch Peru without Peru itself being the target of sanctions. The SDN List, updated frequently by OFAC, includes designated nationals of sanctioned countries who may maintain assets, shell companies, or trade relationships in non-sanctioned jurisdictions, including Peru. Under OFAC’s 50 Percent Rule, any entity owned 50 percent or more in the aggregate by one or more blocked persons is itself treated as blocked, regardless of whether that entity appears on the SDN List. A Peruvian company with a minority blocked owner may not trigger the rule directly, but any transaction that indirectly benefits a blocked person can create OFAC exposure.
In addition to SDN screening, OFAC administers country- and program-based sanctions — including those targeting Iran, North Korea, Syria, Russia, and the Crimea, Donetsk, and Luhansk regions of Ukraine — that can reach transactions routed through Peru. For example, a shipment of goods from a US exporter to a known Peruvian buyer may present OFAC risk if the goods are destined for re-export to a comprehensively sanctioned jurisdiction or if the Peruvian buyer is a front for a blocked entity. US financial institutions processing wire transfers to or from Peruvian banks are required to screen under their own OFAC compliance programs, and a transaction rejected or blocked by an intermediary bank can disrupt a legitimate commercial relationship. Peruvian businesses that access the US financial system — through correspondent accounts, dollar-denominated trade finance, or US-based investors — are well advised to maintain an OFAC compliance framework even if they have no US physical presence. For the obligations applicable to your particular transaction, consult an attorney familiar with both US sanctions law and Peruvian commercial practice.
How Law Offices of SRIS, P.C. Handles Peru-Related OFAC Matters
Law Offices of SRIS, P.C. approaches Peru OFAC compliance as a US-law matter anchored in the International Emergency Economic Powers Act (IEEPA), the Trading with the Enemy Act (TWEA), and the OFAC regulations set out at 31 C.F.R. Chapter V. The firm’s US-licensed attorneys, led by Mr. Sris, advise on the substantive US sanctions law, while the firm’s Of Counsel network in Latin America provides country-specific context on Peruvian corporate structures, regulatory practice, and the UIF-Peru reporting regime. The firm does not represent clients directly before Peruvian regulatory bodies; matters requiring representation under Peruvian law are referred to or handled in collaboration with Peru-admitted counsel. Martín Mayandía, Of Counsel for Peru matters at Law Offices of SRIS, P.C., is admitted to practice law in Peru. He is not admitted to practice law in the United States.
Typical Peru OFAC engagements include pre-transaction SDN screening and risk assessment for US companies entering the Peruvian market, compliance program design for Peruvian financial institutions with US correspondent accounts, voluntary self-disclosure analysis where a potential OFAC violation involving a Peru-linked transaction is identified, and due diligence on Peruvian acquisition targets for US private equity and venture capital funds. The firm also assists with Office of Foreign Assets Control specific license applications where a transaction is otherwise prohibited but qualifies for a licensing exception under OFAC regulations. Every engagement begins with a review of the current sanctions lists, because OFAC designations and general licenses change frequently — a sanctions framework accurate in one quarter may be materially different the next. Clients are advised to verify their compliance posture against the most current OFAC publications available at ofac.treasury.gov.
About Mr. Sris and the Law Offices of SRIS, P.C. Of Counsel Network
Mr. Sris, Owner and Founder of Law Offices of SRIS, P.C., has practiced since 1997 and is admitted to the bar in Virginia, Maryland, the District of Columbia, New Jersey, and New York. His practice encompasses cross-border compliance matters including OFAC sanctions, FCPA anti-bribery compliance, and anti-money laundering program counseling for US and international clients. Mr. Sris testified before the Virginia House Courts of Justice Committee in support of 2019 HB 635 (chief patron Del. David Bulova).
For Peru-related matters, Mr. Sris works closely with the firm’s Of Counsel network in Latin America. Martín Mayandía, Of Counsel for Peru matters at Law Offices of SRIS, P.C., is admitted to practice law in Peru. He is not admitted to practice law in the United States. This collaborative structure allows the firm to address the US-sanctions dimension of a client’s matter through US-licensed counsel while drawing on Peru-specific knowledge from a Peru-admitted attorney who understands the local regulatory environment. Where a matter requires formal representation before Peruvian authorities — such as a filing with the UIF-Peru or a response to a Peruvian regulatory inquiry — the firm coordinates with Peru-admitted counsel to ensure the client receives representation in the correct jurisdiction.
Frequently Asked Questions
Is Peru under US OFAC sanctions?
Peru is not subject to comprehensive US sanctions administered by OFAC. As of mid-2026, there is no OFAC country-based sanctions program targeting Peru, and US persons are generally permitted to engage in trade, investment, and financial transactions with Peruvian counterparties. However, OFAC’s list-based sanctions — principally the SDN List — can affect specific individuals and entities located in or operating through Peru. A transaction that appears to involve Peru may still be prohibited if it directly or indirectly involves a blocked person. US businesses should screen all Peru-linked counterparties against current OFAC lists before proceeding. Sanctions programs are updated frequently; verify the current status at ofac.treasury.gov.
What is the SDN List and how does it affect business with Peru?
The Specially Designated Nationals and Blocked Persons List (SDN List) identifies individuals, entities, and vessels whose assets are blocked and with whom US persons are generally prohibited from dealing. The SDN List is global in scope and not tied to any single country. A Peruvian company may be SDN-listed because of its ownership by a blocked person, its involvement in proliferation networks, its connection to narcotics trafficking, or other designation criteria independent of Peru’s diplomatic status. OFAC’s 50 Percent Rule extends the blocking effect to entities owned 50 percent or more in the aggregate by one or more SDNs. Screening Peruvian counterparties against the SDN List — including their beneficial owners, directors, and intermediate holding companies — is an essential step in any Peru-linked transaction subject to US jurisdiction.
Do I need an OFAC compliance program for my Peru operations?
Any US person or entity engaged in international business should maintain an OFAC compliance program proportionate to its risk profile, including for transactions involving Peru. While Peru itself is not sanctioned, OFAC enforcement actions have targeted companies whose inadequate screening allowed transactions with SDNs operating through non-sanctioned jurisdictions. A reasonable compliance program typically includes SDN screening at onboarding and periodically thereafter, geographic risk assessment, transaction monitoring, and employee training. Peruvian financial institutions that maintain US correspondent accounts face additional expectations under their US bank partners’ compliance requirements and should evaluate whether their existing AML programs adequately address OFAC risk. The appropriate scope of a compliance program depends on transaction volume, counterparty profile, industry sector, and geographic footprint. For guidance tailored to your operations, reach Law Offices of SRIS, P.C. at (888) 437-7747.
What role does Peru’s UIF play in sanctions compliance?
Peru’s Unidad de Inteligencia Financiera (UIF-Peru) is the national financial intelligence unit responsible for receiving, analyzing, and disseminating reports of suspicious transactions under Peru’s anti-money laundering and counter-terrorist financing framework. The UIF operates under Peru’s compliance with FATF standards through GAFILAT. While the UIF does not enforce US OFAC sanctions, it cooperates with international counterparts including FinCEN through the Egmont Group, and information shared by the UIF can inform OFAC investigations and designations. Peruvian businesses subject to UIF reporting obligations — including banks, broker-dealers, notaries, and designated non-financial businesses — should integrate OFAC screening into their broader AML/CFT compliance programs to address both Peruvian regulatory requirements and US sanctions exposure where they access the US financial system.
How can a US attorney help with my Peru OFAC compliance matter?
A US attorney admitted to practice in US federal courts can advise on the application of OFAC regulations, assist with SDN screening framework design, prepare voluntary self-disclosures, and file specific license applications with OFAC. OFAC compliance is a matter of US federal law, and legal advice on the scope and application of US sanctions is properly provided by a US-licensed attorney. Law Offices of SRIS, P.C. provides this US-law advice through Mr. Sris and its US-licensed attorneys, while collaborating with Peru-admitted Of Counsel — Martín Mayandía, Of Counsel for Peru matters at Law Offices of SRIS, P.C., is admitted to practice law in Peru. He is not admitted to practice law in the United States — for context on Peruvian regulatory practice and local corporate structures. This structure ensures the US-law analysis is handled by US-licensed counsel while the client benefits from Peru-specific knowledge.