On October 24, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated the President of Colombia, Gustavo Francisco Petro Urrego, on the list of Specially Designated Nationals and Blocked Persons (the SDN List) pursuant to Executive Order 14059 for his involvement in the global illicit drug trade. Additionally, OFAC designated President Petro’s wife (Verónica Alcocer), son (Nicolás Petro), and Interior Minister (Armando Benedetti). OFAC’s designation of President Petro follows President Trump’s September 15, 2025, determination that Colombia, among other countries, is a “major drug transit or major illicit drug producing” country under Section 706(1) of the Foreign Relations Authorization Act.
OFAC sanctions on these Colombian individuals, however, do not automatically extend to ministries of the Colombian government, the entirety of the Colombian government, or Colombia itself. This distinction is important because US persons (and non-US persons where there is a US nexus) are generally prohibited from engaging in or facilitating dealings with President Petro, but not ministries of the Colombian government, the Colombian government, or non-sanctioned persons located in Colombia as a result of these sanctions.
To help mitigate the potential risk of breaching US sanctions targeting President Petro, his family, and his support network, companies with activities relating to Colombia might consider reviewing such business to identify and avoid potentially prohibited dealings. For example, companies engaging with the Colombian government might consider taking steps to avoid negotiating with, countersigning contracts with, or undertaking other dealings with President Petro or other blocked persons.
Distinguishing the Colombian Individuals, Government, and Country
In connection with past sanctions, OFAC issued guidance that may help companies distinguish between unlawful dealings with sanctioned Colombian individuals, as distinct from permissible activities related to the Colombian government or the territory of Colombia. For example, OFAC FAQ 993 states that a designated official’s leadership position does not automatically result in sanctions on the government or institution they lead. In contrast, OFAC has been unambiguous when it imposes sanctions on a government ministry (e.g., the Ministry of Defense of Burma), an entire government (e.g., the Venezuelan government), and an entire territory (e.g., Cuba).
OFAC has cautioned that while US persons may negotiate with a government that includes sanctioned officials, it is unlawful to negotiate directly with a blocked person, even in their official capacity. Along the same lines, OFAC FAQ 398 states that it is unlawful for US persons to enter into a contract that is signed by a blocked person.
Considerations for Companies with Activities Related to Colombia
To help assess and address potential risks, companies with activities related to Colombia might consider taking the following steps:
- Sanctions screening: screen names of parties involved in Colombia-related activities. Additionally, before meetings or negotiations related to such activities, identify attendees and screen their names against OFAC’s SDN List;
- Training: provide updated sanctions training and practical guidance for teams working on Colombia-related projects to help avoid unlawful dealings with Colombian sanctioned persons;
- Due diligence: assess touchpoints with the Colombian government, including analyzing contracts, avoiding certain dealings if necessary, and regularly reviewing ownership and management structures of counterparties (where ownership structures are unclear, transactions should be escalated to sanctions counsel or compliance officers for review); and
- Compliance representations, undertakings, and certifications: analyze and, if possible, update contracts to include robust sanctions compliance and termination clauses, or otherwise obtain sanctions compliance certifications.
Conclusion
Sanctioning a head of state can be a politically sensitive measure; however, it remains a targeted action generally aimed at the individual and their network, not the country or government itself. Companies might consider reviewing their Colombia-related activities and undertaking the steps above to help comply with these new sanctions.
