Foreign Sourcing & Buy American (Part 25)

FAR 52.225-13

Restrictions on Certain Foreign Purchases

Prohibits acquisition of supplies or services from sources sanctioned by OFAC under the Office of Foreign Assets Control programs (Cuba, Iran, North Korea, Syria, Russia (various sectoral lists), and others), Specially Designated Nationals (SDN) list, sectoral sanctions lists, and entities under various entity lists.

FAR / DFARS Part
FAR Part 25 — Foreign Acquisition
Prescribed By
FAR 25.1103(a) — Required in all solicitations and contracts.
Flow-down to Subcontracts

Yes — flow down to all subcontracts (52.225-13(c)).

What this clause requires

  • 1Do not acquire supplies or services from prohibited sources (OFAC sanctioned countries, SDN List, BIS Entity List, etc.).
  • 2Continuous screening — sanctioned-party lists are updated daily.
  • 3Flow down to all subcontracts.
  • 4Maintain documentation of due diligence on supplier countries-of-origin and ownership.

When this clause applies

Every Federal contract. No dollar threshold. Sanctions landscape changes frequently — especially post-2022 Russia sanctions.

Common pitfalls

!Treating screening as a one-time check — OFAC, BIS, and State Department lists update constantly.
!Failing to screen ultimate-beneficial-owner ownership — 50% rule on OFAC blocked entities reaches subsidiaries.
!Missing General Licenses that authorize narrow transactions — over-blocking is also a compliance risk.
!Not flowing down — primes are responsible for sub-tier compliance.

Proposal-team checklist

  • ☐Implement automated daily screening against OFAC, BIS, OFSI, and State Department lists.
  • ☐Document the screening process and retain results for the regulatory retention period.
  • ☐Build a process to refresh screening when scope changes mid-contract.
  • ☐Add 52.225-13 flow-down language to every subcontract template.

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FAQ

Is screening just SDN list?

No. OFAC has 25+ sanctions programs (Cuba, Iran, DPRK, Syria, Russia, Belarus, Venezuela, Sudan, etc.) plus the SDN list. BIS Entity List, State DDTC, EU/UK sanctions all overlap. Use a commercial screening tool.

Are there exceptions?

Narrow exceptions exist — General Licenses, humanitarian carve-outs, and authorized transactions. All require legal review before reliance.

Related clauses

FAR 52.204-25
Section 889 Part A & B Prohibition

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Reference content based on the Federal Acquisition Regulation and DFARS as of June 2026. Always verify the current clause text at acquisition.gov before relying on it for an actual submission. Educational reference; not legal advice.