An oil exploration company based in France does business with oil refineries in Iran, which is subject to comprehensive Office of Foreign Assets Control (OFAC) sanctions. What type of OFAC sanctions…

Sectoral sanctions restrict specific economic sectors within a target country (for example, Russia's energy or financial sector) and do not apply to third-country companies transacting with comprehensively sanctioned states.

Country-based (primary) sanctions prohibit US persons and entities from dealings with the sanctioned country; they do not directly reach foreign companies like the French firm that lack a US nexus.

Secondary sanctions allow the US to penalize foreign entities that engage in business with sanctioned countries or parties, even when those entities have no direct US connection. Because the French company is operating outside US jurisdiction but dealing with Iran - a comprehensively sanctioned country - OFAC can impose secondary sanctions to deter circumvention of its primary Iran sanctions program.

List-based sanctions designate specific named individuals or entities on lists such as the SDN list; the French company would only be subject to these if it were formally designated, not merely for doing business with Iran.