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Learning Hub

How sanctions operate

What a sanction does, what puts a firm inside it, and where the answer is written down. Part one answers the question in about two minutes. Parts two to seven are the reference underneath it: the kinds of measure and the conduct that triggers each, the thematic regimes, the published enforcement record and the source routing. The five-regime comparison closes the page.

Structure as at 1 September 2026Re-verified quarterly against the official texts

This explains how sanctions regimes are constructed, what each kind of measure does, and where the regimes diverge. It is not legal advice, it states no view on whether any particular party or transaction is caught, and it deliberately contains no statement of who is designated today — list state changes weekly and belongs at the official sources cited throughout.

Read against Regulation (EU) No 833/2014 in its consolidated version of 24 July 2026 (CELEX 02014R0833-20260724), Regulation (EU) No 269/2014, Regulation (EU) 2020/1998 as adopted, SI 2019/855, SI 2020/680, SI 2021/488, the Embargo Act (SR 946.231, status 1 July 2023), Executive Order 13818 (82 FR 60839) and 31 C.F.R. part 583.

Part one

The operating model, in six statements

These six hold across all five regimes. This is the short answer; the rest of the page is the detail underneath it.

01

The decision is political. The instrument is what binds you.

A council, a minister or a president decides to sanction. That decision has no effect on a private party until it is written into an instrument that applies where the party is: a Council Regulation in the EU, a statutory instrument in the UK, a Federal Council ordinance in Switzerland, an Executive Order and OFAC regulations in the United States. A UN Security Council resolution binds member states and never binds a bank directly. The obligation you owe is the one in the instrument.

02

A measure does one of a small number of things.

It freezes assets. It bans supplying value to a person. It bans trade in named goods. It bans a named service. It bans access — to ports, to airspace, to roads, to capital markets. It bans a person's entry to the country. A sanctions package is a combination of these, assembled and re-assembled by amendment.

03

Three things put you in scope: who you are, what you do, and who you deal with.

Who you are is your nationality, your place of incorporation, and where you are standing when you act. What you do is your industry, your service line, your cargo and your settlement currency. Who you deal with is your counterparty and whoever owns or controls them. Name screening addresses the third. The first two are settled before any name is checked.

04

The list is not the law.

A list is an administrative compilation published so that names can be found. The prohibition sits in the instrument. Two consequences follow directly. A company that appears on no list is frozen where a designated person owns or controls it. A name that matches a list entry is not a conclusion — it is a reason to open the designating instrument and identify the person against the identifiers it gives.

05

Permission exists, and it is obtained before the payment.

A freeze is not confiscation. Salaries, legal fees, insurance, basic living costs, humanitarian supply and the winding-down of pre-existing contracts move under a licence or a derogation. Each instrument names the authority that grants it. In the UK that authority is OFSI. In the EU it is the competent authority of the member state, listed in the Regulation's own annex, and not the Commission.

06

The fine and the prosecution come from different bodies on different standards.

An administrative regulator imposes monetary penalties on the civil standard. A prosecutor brings criminal charges on the criminal standard. The same facts can produce both. In the UK those bodies are OFSI and the Crown Prosecution Service. In the United States they are OFAC and the Department of Justice. In Switzerland the Embargo Act provides criminal penalties and no civil penalty regime of the OFSI kind.

Part two

What a sanction can do, and what puts you inside it

Each entry states the measure, the conduct that triggers it, and — where the negative is the useful half — what does not trigger it. The examples are drawn from the instruments cited beneath each one.

Targeted asset freeze

Every asset of a designated person that is within your control stops moving, on the day of designation, without notice to you.

You are caught if

You hold, owe or control anything belonging to, owned, held or controlled by a designated person. That includes an account, an unpaid invoice, goods in a warehouse, a shipment in transit, an insurance policy, an entry on a share register and a tenancy.

Not decided by

Whether the designated person is your customer. The freeze attaches to the asset, not to the relationship.

Making funds or economic resources available

A second and wider prohibition sitting beside the freeze: it bans supplying value to a designated person rather than holding their assets.

You are caught if

You pay, lend, supply, deliver, insure or release anything of value to a designated person or for their benefit, directly or indirectly. "Economic resources" means assets of every kind that are not funds but can be used to obtain funds, goods or services, so a delivery of goods and a release of collateral both count.

Not decided by

Whether money moves, and whether the designated person is a party to your contract. A payment to an intermediary that reaches a designated person is within the prohibition.

Transaction ban on a named entity

Bans dealing with a listed entity outright, without freezing that entity's assets.

You are caught if

Your counterparty appears in the annex to the transaction-ban article. In Regulation (EU) No 833/2014 that is Annex XIX, and the prohibition covers any transaction, directly or indirectly.

Not decided by

A designation. These entities are not asset-frozen, so a screen against the asset-freeze list does not return them.

Capital-market restrictions

Bans a class of dealing in the securities and money-market instruments of named institutions, by reference to the date the instrument was issued.

You are caught if

You purchase, sell, provide investment services for, assist in the issuance of, or otherwise deal with transferable securities or money-market instruments issued by the listed institutions after the dates set out in the article, or by an entity established outside the Union whose proprietary rights are more than 50% owned, directly or indirectly, by a listed institution.

Not decided by

The identity of the person you trade with. The trigger is the issuer and the issue date of the paper.

Export bans on goods and technology

Bans the sale, supply, transfer or export of listed goods and technology to a destination.

You are caught if

You sell, supply, transfer or export goods or technology on the annexed lists to that country, or to any person for use there. Dual-use goods and technology are one list; goods that could contribute to military and technological enhancement are another.

Not decided by

Your buyer's name. The goods and the destination decide it. Since 20 March 2024 an EU exporter of certain listed items to a third country must additionally prohibit re-export to Russia by contract.

Import bans

Bans the purchase, import or transfer of listed goods by reference to where they originate or were exported from.

You are caught if

You purchase, import or transfer listed goods originating in, or exported from, the covered country. Crude oil and petroleum products, gold, diamonds and a schedule of revenue-generating goods each sit in their own article with their own dates.

Not decided by

Your counterparty's nationality. Origin decides it, and origin survives an intermediate sale.

Services bans

Bans the provision of named professional services to a government or to persons established in the covered country.

You are caught if

You provide legal advisory, accounting, auditing, bookkeeping, tax consulting, business or management consulting, public relations, construction, architectural, engineering, urban planning, technical testing and analysis, advertising, market research, public opinion polling, IT consultancy, or commercial Earth-observation or satellite-navigation services to the Government of Russia or to a legal person, entity or body established in Russia.

Not decided by

A designation, a payment, or a financial exposure of any kind. This is the article that reaches accountants, consultants, engineers and law firms who hold no assets and move no money.

Access and transport bans

Closes ports, airspace and roads to defined vessels, aircraft and hauliers.

You are caught if

You give access to a port or lock in the Union to a vessel registered under the flag of Russia or certified by the Russian Maritime Register of Shipping; or a Russian-operated, Russian-registered or Russian-owned, chartered or controlled aircraft lands in, takes off from or overflies Union territory on your operation; or you are a road transport undertaking established in Russia moving goods within the Union, or an EU undertaking 25% or more Russian-owned seeking admission as one.

Not decided by

Ownership alone in the vessel case: the flag and the classification society are the tests, and a change of flag after 24 February 2022 does not clear the ban.

Shipping and insurance measures tied to a price cap

Bans the services that move a commodity, and then releases them by derogation for cargoes sold at or below a set price.

You are caught if

You provide technical assistance, brokering services, financing, financial assistance or insurance related to the trading, brokering or transport of Russian-origin crude oil or petroleum products to third countries.

Not decided by

Nothing about the counterparty. The cap price itself is amended by later Council acts, so the figure is read from the current consolidated text and not from memory.

Territorial measures

Applies restrictions by reference to a territory rather than to a counterparty or a designation.

You are caught if

You import goods originating in the covered territory, or invest, or supply infrastructure, transport, telecommunications or energy services there. The counterparty's identity does not enter the test.

Travel bans

Suspends the entry and transit of a designated individual.

You are caught if

The designated individual is caught. A firm is not. A travel ban ordinarily sits in the same instrument as the asset freeze and is imposed on the same designation, which is why an asset-freeze list and a travel-ban list overlap without being identical.

  • Executive Order 13818 The law82 FR 60839, s. 2 — entry suspended under s. 212(f) of the Immigration and Nationality Act

Secondary sanctions

Designates a non-US person for dealing with a sanctioned party, where no US jurisdiction over the dealing exists.

You are caught if

You are not a US person, your transaction has no US nexus, and you engage in a significant transaction with a sanctioned party under a programme that provides for it. The consequence is your own designation, not a penalty — the sanction is imposed on you rather than enforced against you.

Not decided by

Any US touchpoint. That is the definitional feature: primary jurisdiction requires a nexus, secondary designation does not.

Circumvention, and the duty over entities you control

Reaches conduct designed to defeat the measures, and pushes a duty onto EU parents in respect of non-EU subsidiaries.

You are caught if

You participate knowingly and intentionally in activities whose object or effect is to circumvent a prohibition. Separately, you own or control a legal person established outside the Union and do not use best efforts to ensure it does not participate in activities undermining the measures.

Part three

The regimes beyond these five

The UN, EU, UK, Swiss and US regimes are the five this hub sets out. They are not the whole set. Every UN member state is obliged to give effect to Security Council measures in its own law, and many states additionally run autonomous regimes of their own, with their own designation criteria, their own lists and their own jurisdiction clauses. A regime binds a party when its own nexus test reaches that party. Screening five lists answers for five regimes.

Australia

The Australian Sanctions Office, in the Department of Foreign Affairs and Trade. Thematic designation for human rights, serious corruption, malicious cyber activity and serious violations of international humanitarian law has been available since 8 December 2021.

Canada

Global Affairs Canada. Canada runs a dedicated Magnitsky statute alongside its general economic-measures Act.

Part four

Thematic regimes: human rights, and corruption

A country regime is triggered by a place. A thematic regime is triggered by conduct, anywhere in the world, and is not confined to any country. The human-rights regimes below share a name in common usage and do not share a scope: the conduct that brings a person within one of them will not always bring the same person within another.

US

United States — Global Magnitsky

Conduct in scope
Serious human rights abuse, which the Executive Order does not itself define. The Order reaches a foreign person responsible for, complicit in, or who has directly or indirectly engaged in it; a leader or official of an entity that engaged in it during their tenure; a person who attempted it; and a person who materially assisted, sponsored, or provided financial, material or technological support for, or goods or services to or in support of, that activity or a blocked person, or who is owned or controlled by, or has acted or purported to act for, a blocked person.
Corruption
In the same instrument. The corruption limb covers misappropriation of state assets, expropriation of private assets for personal gain, corruption related to government contracts or the extraction of natural resources, bribery, and the transfer or facilitation of transfer of the proceeds of corruption — but only where the person is a current or former government official, or acting for one.
Who designates
The Secretary of the Treasury, in consultation with the Secretary of State and the Attorney General.
Who administers
OFAC, under 31 C.F.R. part 583.
Reach
All property and interests in property that are in the United States, that come within the United States, or that are or come within the possession or control of any US person. Entry to the United States is separately suspended.
UK

United Kingdom — Global Human Rights

Conduct in scope
Three rights, and no others. An activity is within scope if, were it carried out by or on behalf of a State within that State's territory, it would amount to a serious violation by that State of an individual's right to life; right not to be subjected to torture or cruel, inhuman or degrading treatment or punishment; or right to be free from slavery, not to be held in servitude or required to perform forced or compulsory labour — whether or not the activity is in fact carried out by or on behalf of a State. An activity includes an omission. Regulation 4(3) confines the regime to activity carried out outside the United Kingdom by any person, or in the United Kingdom by a person who is not a UK person.
Corruption
In a separate instrument. The Global Anti-Corruption Sanctions Regulations 2021 cover bribery of a foreign public official and misappropriation of property by a foreign public official. Conduct outside both instruments is outside the UK's thematic regimes.
Who designates
The Secretary of State, in practice the FCDO.
Who administers
OFSI, for financial sanctions.
Reach
Conduct in the United Kingdom, and conduct anywhere in the world by a UK person — a British national, or a body incorporated or constituted under the law of any part of the UK (SAMLA 2018, s. 21).
EU

European Union — Global Human Rights

Conduct in scope
Genocide; crimes against humanity; and the serious violations or abuses listed in Article 2(1)(c) — torture and other cruel, inhuman or degrading treatment or punishment, slavery, extrajudicial, summary or arbitrary executions and killings, enforced disappearance, and arbitrary arrests or detentions. Article 2(1)(d) adds further violations, including trafficking in human beings, sexual and gender-based violence, and violations of freedom of peaceful assembly and association, of opinion and expression, and of religion or belief — but only where they are widespread, systematic or otherwise of serious concern to the CFSP objectives in Article 21 TEU. Designation can reach State actors, actors exercising effective control over a territory, and non-State actors.
Corruption
Absent. Regulation (EU) 2020/1998 does not cover corruption. A dedicated CFSP regime for serious acts of corruption was proposed by the High Representative and the Commission on 3 May 2023 as JOIN(2023) 13 final; the European Parliament recorded on 21 January 2026 that the file is blocked at the Council. A CFSP instrument requires unanimity.
Who designates
The Council, acting by unanimity on a CFSP Decision.
Who administers
The competent authority of each member state, identified on the websites listed in the Regulation's Annex II. There is no EU-level administering body.
Reach
Within Union territory including its airspace; on board aircraft and vessels under a member state's jurisdiction; to any national of a member state inside or outside the Union; to any legal person incorporated or constituted under a member state's law; and to any legal person in respect of business done in whole or in part within the Union (Art. 19).
CH

Switzerland — under the Embargo Act

Conduct in scope
Determined by the instrument Switzerland adopts. Article 1(1) of the Embargo Act empowers the Confederation to enact compulsory measures to implement sanctions ordered by the United Nations, by the OSCE, or by Switzerland's most significant trading partners, where those sanctions serve to secure compliance with international law and in particular respect for human rights. Article 1(2) reserves the Federal Council's separate constitutional power to take measures to safeguard the interests of the country.
Corruption
Follows the adopted instrument on the same basis. Switzerland's route into a thematic designation runs through an ordinance implementing another body's measure.
Who designates
The Federal Council, by ordinance, one regime at a time. Adoption of an EU package is a fresh decision on each occasion.
Who administers
SECO.
Reach
The scope article of the ordinance in question. Swiss measures apply in Switzerland; there is no general nationality-based extraterritorial rule of the EU or UK kind.

How these are enforced

A thematic designation carries no separate enforcement machinery. Once a person is designated under a human-rights or anti-corruption regime, the prohibitions that attach are the ordinary ones — the asset freeze and the making-available ban of that jurisdiction — and a breach is penalised through the ordinary route: an OFSI monetary penalty or a prosecution in the UK, an OFAC civil penalty or a Department of Justice prosecution in the United States, a national penalty in an EU member state. The published enforcement records set out in Part five are therefore the record for these regimes too; neither OFSI nor OFAC reports its penalties broken down by the regime the designation came from.

Part five

Has it been enforced

Per regime: the direct answer, and where the official record of enforcement is kept. No penalised party is named here; the citations lead to the published records.

UK

United Kingdom

Yes, on both tracks. OFSI has imposed monetary penalties since its first in January 2019; the largest it has published is £20.47m, imposed on 18 February 2020. On the criminal track, the Crown Prosecution Service records the first UK prosecution for breaches of the Russia sanctions regime, with sentencing at Southwark Crown Court on 11 April 2025: eight counts of breaching financial sanctions and two of money laundering against one defendant, sentenced to 40 months' imprisonment, and a suspended sentence for a second defendant on two counts.

OFSI publishes every monetary penalty it imposes, and separately publishes disclosure notices where it finds a breach without imposing a penalty.

US

United States

Yes, continuously and for far longer. OFAC publishes each civil penalty and settlement it imposes, arranged by year, and the series runs back over two decades. Civil penalties under IEEPA do not require proof of intent; criminal liability requires a wilful violation and is brought by the Department of Justice.

OFAC's civil penalties and enforcement information page, browsable by year, with the enforcement release for each action.

EU

European Union

Enforcement is national, and there is no EU-level penalty register to read. Regulations require member states to lay down effective, proportionate and dissuasive penalties, which produced wide variation between them. Directive (EU) 2024/1226 defines the criminal offences and penalty levels member states must provide for violations of Union restrictive measures.

Each member state's own competent authority and prosecuting authorities. The Regulation's Annex lists the competent authority for each state.

CH

Switzerland

Criminal, not civil. Article 9 of the Embargo Act makes wilful violation of a provision of a sanctions ordinance an offence carrying a custodial sentence not exceeding one year or a monetary penalty, rising to five years in serious cases. Negligent commission carries a fine not exceeding CHF 100,000. There is no administrative monetary-penalty regime of the OFSI kind.

Proceedings run under Swiss administrative criminal procedure, with SECO as the prosecuting authority for breaches.

  • Embargo Act (EmbA) The lawSR 946.231, Art. 9 (felonies and misdemeanours), Art. 10 (contraventions) — status as of 1 July 2023
UN

United Nations

Not against private parties. The Security Council monitors state implementation through its Committees and panels of experts. A penalty against a firm comes from national law.

Committee reports and panel of experts reports.

Part six

The questions, answered

Each answer states the rule and points at the provision. None states whether a described party is caught — that is advice, and this is not the surface for it.

The name matched. Is that a hit?

No. A list entry is a name with identifiers — dates of birth, passport numbers, addresses, aliases. A match on name alone is a reason to compare the identifiers against the designating instrument. The instrument states who is designated; the list is the finding aid that helps you locate the entry.

The company is on no list. Are we clear of it?

Not by that fact alone. Every implementing regime reaches unlisted companies through the persons who own or control them. OFAC's published rule blocks an entity owned 50 percent or more, in the aggregate, by one or more blocked persons, whether or not OFAC has named it. The UK test is more than 50 percent of shares or voting rights, or the ability to appoint or remove a majority of the board, or the ability to ensure the affairs of the body are conducted in accordance with a person's wishes. The EU treats ownership and control as separate limbs, either of which suffices.

We are not a US company and we clear no dollars. Does OFAC reach us?

By two separate routes, and they are not alternatives to each other. The primary route needs a US nexus: a dollar payment clearing a US correspondent bank, US-origin goods or technology, US-based infrastructure, or a US person approving, financing or otherwise facilitating the transaction from anywhere in the world. The secondary route needs none: under the programmes that provide for it, a non-US person who engages in significant transactions with a sanctioned party may itself be designated.

Our subsidiary is outside the EU. Does the Regulation reach it?

The Regulation applies within Union territory, on board aircraft and vessels under a member state's jurisdiction, to nationals of member states wherever they are, to legal persons constituted under a member state's law, and to any legal person in respect of business done in whole or in part within the Union. A subsidiary constituted outside the Union is not caught by those limbs on its own account. Separately, Article 8a requires you to use best efforts to ensure a legal person established outside the Union that you own or control does not participate in activities that undermine the measures.

Can a designated person's salary, legal fees or insurance be paid?

Under a licence or a derogation, obtained in advance from the authority the instrument names. In the UK that is OFSI. In the EU it is the competent authority of the member state, identified on the websites listed in the Regulation's annex — not the Commission, and not a single EU authority. Paying first and applying afterwards is a breach with a licence application attached to it.

We only advise. No money moves through us. Are we in scope?

Where a services ban applies, yes. Article 5n of Regulation (EU) No 833/2014 prohibits providing legal advisory, accounting, auditing, bookkeeping, tax consulting, business and management consulting, public relations, construction, architectural, engineering, advertising, market research, IT consultancy and certain space-based services to the Government of Russia or to a legal person, entity or body established in Russia. No designated person and no payment is required for the prohibition to apply.

We did not know. Does that help?

It depends on the regime and on which kind of liability is in issue. Under Regulation (EU) No 833/2014, actions do not give rise to liability if the party did not know and had no reasonable cause to suspect that they would infringe the measures. In the UK, OFSI may impose a monetary penalty without establishing knowledge or reasonable cause to suspect: the Economic Crime (Transparency and Enforcement) Act 2022 removed that test with effect from 15 June 2022. US civil penalties under IEEPA do not require intent, while criminal liability requires wilfulness. The Swiss offence requires wilfulness, with negligence separately punishable by a fine.

Which regime applies to us?

Every regime whose jurisdiction clause reaches you, at the same time, with no order of precedence between them. Count the nexuses rather than choosing one: place of incorporation, nationality of the individuals acting, physical location of the conduct, currency of settlement, origin of the goods or technology, location of the servers, and the flag of the vessel. Two regimes reaching the same transaction can require different things of you, and in the case of the Blocking Statute they can require opposite things.

Part seven

Where to look, by question

The routing, before the question comes up.

Is this person designated, and on what grounds?

The designating instrument — the Official Journal text, the statutory instrument, the ordinance, or the Executive Order. Find the entry through the official list, then read the instrument behind it. The list gives the identifiers; the instrument gives the grounds.

Does the prohibition reach me?

The application or jurisdiction article. In an EU Regulation it is the penultimate article. In the UK it is section 21 of SAMLA together with the regulation's own extent provision. In Switzerland it is the ordinance's scope article. In the United States it is the definition of "United States person" in the relevant part.

Part eight

Work it, rather than read it

Two exercises built on the same instruments cited above.

Walk through · 10 minutes

One payment, four regimes

A single hypothetical payment, put to the EU, UK, Swiss and US regimes at once. The four answers separate at four points: jurisdictional reach, a 70% shareholding, the authority that may licence the payment, and the mental state required for liability.

Start the walkthrough →

Practise

Designation cases, worked

Judgments of the UK and EU courts, three a day with model answers. Each is read for what it decides on its own facts, and for the wider proposition a careless citation would attribute to it.

Start the exercises →

Part nine · the comparison in full

The five regimes, and who runs each

Four of these bind private parties directly. The UN does not: a Security Council measure reaches a firm only through one of the implementing regimes below.

Structure as at 24 August 2026, verified as recorded under each axis.

UN

United Nations

UN Security Council, through its Sanctions Committees

The apex layer. The Security Council designates; it does not enforce against private parties. Every UN measure reaches a bank or a company only once a member state has implemented it in its own law — which is why the four regimes below exist at all.

EU

European Union

The Council of the EU designates; national competent authorities enforce

Two instruments, always in that order: a CFSP Decision agreed unanimously, then a Regulation that makes it directly binding on private parties. There is no EU-level OFSI — licensing and enforcement sit with each member state's own competent authority.

UK

United Kingdom

FCDO designates; OFSI (HM Treasury) administers financial sanctions

Post-Brexit the UK runs an autonomous regime under its own framework Act, with a country or thematic statutory instrument for each regime. OFSI is the single financial-sanctions authority — licensing, reporting and civil enforcement in one body, which is the sharpest institutional contrast with the EU.

CH

Switzerland

The Federal Council enacts ordinances; SECO administers

Switzerland is not an EU member and is bound by no EU act. It implements UN measures as a UN member, and adopts EU packages by an autonomous decision of the Federal Council each time — which can mean a lag, and can mean differences.

US

United States

The President acts by Executive Order; OFAC (Treasury) administers

The widest reach of the five, by design. A national-emergency statute delegates broad power to the President; OFAC writes the regulations, runs the lists, issues the licences and imposes the civil penalties. Reach extends past US persons through dollar clearing and, separately, through secondary sanctions on non-US parties.

Part ten

Eight questions that decide the answer

Ask these of each regime separately. An answer from one regime is not an answer from another.

01 · Where does the power to designate come from?

Legal base and who designates

Everything downstream follows from the instrument. It sets who can add a name, how fast, what a challenge looks like, and which court hears it. Two of these regimes need a political consensus before anything happens; one needs a single signature.

UN

Security Council resolution under Chapter VII

The Council acts under Article 41 of the Charter and delegates the maintenance of each list to a subsidiary Sanctions Committee. A resolution binds member states, not private parties — the obligation on a bank arises from its own state's implementing law.

EU

CFSP Decision (unanimity), then a Council Regulation

A Decision under Article 29 TEU sets the policy and requires unanimity in the Council. Where it touches economic relations with third countries, a Regulation under Article 215 TFEU then follows on a joint proposal of the High Representative and the Commission. The Regulation is what binds private parties, directly and without national transposition.

UK

SAMLA 2018 framework Act, plus regulations per regime

SAMLA gives an appropriate Minister the power to make sanctions regulations for stated purposes, and each regime — country or thematic — is its own statutory instrument. Designations are made by the Secretary of State (in practice the FCDO); OFSI administers what follows.

CH

Embargo Act, then a Federal Council ordinance per regime

The Embargo Act empowers the Federal Council to enact coercive measures to implement sanctions decided by the UN, the OSCE, or by Switzerland's most significant trading partners. Each regime is a separate ordinance in the Classified Compilation. Nothing arrives automatically: adopting an EU package is a fresh Federal Council decision every time.

US

National emergency declared by Executive Order under IEEPA

The President declares a national emergency under the National Emergencies Act and invokes IEEPA to block property. The Executive Order creates the programme; OFAC issues the implementing regulations in 31 C.F.R. chapter V and adds names to the SDN List. Some programmes are additionally built on their own statutes.

Where they diverge

Speed is the practical difference. A US programme can be created by Executive Order overnight. An EU listing needs unanimity among 27 member states for the CFSP Decision before the Regulation can follow — which is why EU packages arrive in negotiated batches, and why the Swiss decision to match one comes later again.

2026-08-24 — checked against the official consolidated texts on un.org, EUR-Lex, legislation.gov.uk, Fedlex and uscode.house.gov.

02 · Who is actually bound by it?

Jurisdictional reach — the nexus test

Each regime draws its net differently: one by territory, two by nationality plus territory, one by a combination that catches a payment for touching a US correspondent bank. A party can sit outside three of these regimes and inside the fourth on the same facts.

UN

Binds states, not private parties

A UN measure creates an obligation on member states to give effect to it. No bank, company or individual is bound by the resolution as such; they are bound by whichever of the implementing regimes below reaches them. This is why the UN list and a national list rarely match exactly.

EU

EU territory, EU nationals worldwide, EU-incorporated entities, and business done in the Union

The standard jurisdiction clause in an EU sanctions Regulation applies it within EU territory, on board aircraft and vessels under a member state's jurisdiction, to any national of a member state inside or outside EU territory, to any legal person incorporated or constituted under a member state's law, and to any legal person in respect of any business done in whole or in part within the Union. That last limb catches non-EU companies for their EU-facing business.

UK

Conduct in the UK, and UK persons wherever in the world they are

UK sanctions regulations reach conduct in the United Kingdom, and — expressly — conduct anywhere in the world by a UK person: a British national, or a body incorporated or constituted under the law of any part of the UK. A UK-incorporated subsidiary abroad carries the regime with it.

CH

Territorial — measures apply in Switzerland

Swiss sanctions ordinances apply within Switzerland, to persons and assets there. Switzerland does not run a general nationality-based extraterritorial rule of the EU or UK kind, so the practical question is whether the conduct, the assets or the institution are in Switzerland — not what passport the actor holds.

US

US persons worldwide, anyone in the US — plus any transaction with a US nexus

"US person" covers US citizens and permanent residents wherever located, entities organised under US law including their foreign branches, and any person physically in the United States. Beyond that, a transaction is caught by its nexus: dollar payments clearing through a US correspondent bank, US-origin goods or technology, US-based servers, or a US person facilitating from abroad. Some programmes reach foreign subsidiaries of US companies as well.

Where they diverge

Switzerland is territorial where the EU and UK are not: a Swiss ordinance reaches conduct in Switzerland, while an EU Regulation follows a member-state national anywhere in the world and a UK regulation follows a UK person anywhere in the world. So a UK national working in Zurich can be bound by UK sanctions on conduct that Swiss law does not reach at all — and vice versa. Assuming one screen answers for both is exactly the mistake.

2026-08-24 — jurisdiction clauses checked against the official consolidated texts; the EU clause read in Council Regulation (EU) No 833/2014, the UK position in SAMLA 2018, the Swiss position in the Embargo Act, the US position in 31 C.F.R. ch. V.

03 · What is actually prohibited?

The freeze, and the making-available prohibition beside it

The freeze is one prohibition of two. Every one of these regimes carries a separate and wider prohibition on making funds or economic resources available, directly or indirectly, to or for the benefit of a designated person. That second prohibition reaches payments to third parties, and goods, services and credit that never touch the designated party's own account.

UN

Freeze and no-making-available, as an obligation on states

The standard UN asset-freeze formula requires states to freeze funds and economic resources of listed parties and to ensure that no funds are made available, directly or indirectly, to or for their benefit. It reaches a private party only through the implementing law.

EU

Freeze all funds and economic resources; make nothing available directly or indirectly

The two prohibitions sit side by side in the operative article of the asset-freeze Regulation: freeze everything belonging to, owned, held or controlled by a listed person, and make no funds or economic resources available to them or for their benefit. "Economic resources" is broad — assets of every kind that can be used to obtain funds, goods or services.

UK

Asset freeze, plus separate offences for making funds and economic resources available

UK regulations split the prohibitions across several regulations: the freeze itself, then distinct prohibitions on making funds available to a designated person, making funds available for their benefit, and the same pair again for economic resources. They are drafted separately because they are separately chargeable.

CH

Freeze and no-making-available, set out in the regime ordinance

Each Swiss ordinance carries its own freeze article and its own prohibition on making funds and economic resources available to listed persons, drafted closely on the EU model where the ordinance implements an EU package. Read the ordinance for the regime in question — the articles are not numbered alike across ordinances.

US

Property is blocked; all dealings prohibited — including facilitation

The US frames it as blocking: all property and interests in property of a designated person that come within the United States or within the possession or control of a US person are blocked, and virtually all transactions in that property are prohibited absent a licence. US persons are separately prohibited from approving, financing or otherwise facilitating a transaction by a foreign person that a US person could not do directly.

Where they diverge

The structure is strikingly consistent across all four implementing regimes — freeze plus a making-available prohibition, both reaching indirect benefit. The US adds an express prohibition on facilitation by a US person, which is what catches an American compliance officer approving a transaction their non-US employer executes.

2026-08-24 — checked against Council Regulation (EU) No 269/2014, SI 2019/855, the Swiss Ukraine ordinance (SR 946.231.176.72) and 31 C.F.R. ch. V.

04 · Is a company caught because of who owns it?

Ownership and control — the ownership tests compared

Almost no sanctions problem is about a listed individual's own account. It is about a company that is not listed, owned or controlled by someone who is. Every regime extends to those companies — but by different tests, producing different answers on the same corporate structure.

UN

Owned or controlled, directly or indirectly — applied by states

The UN freeze formula extends to funds owned or controlled directly or indirectly by listed persons, or by persons acting on their behalf or at their direction. How that is tested in practice is a matter for the implementing regime.

EU

Ownership above 50%, OR control on a separate set of indicators

The Council's Best Practices paper treats ownership as more than 50 percent of proprietary rights or a majority interest, and treats control as a separate question answered on indicators — the power to appoint or remove a majority of the board, to direct the company's affairs, or to use all or part of its assets. Either limb can bring an unlisted entity within the freeze.

UK

More than 50% of shares or voting rights, OR the ability to direct the company's affairs

The UK test is set out in the regulations themselves rather than left to guidance. A person owns or controls a body corporate if they hold more than 50 percent of the shares or voting rights, or can appoint or remove a majority of the board — or if it is reasonable to expect that they would be able to ensure the affairs of the body are conducted in accordance with their wishes. That last limb is deliberately wide.

CH

Follows the ordinance — control tests drafted on the EU model where an EU package is adopted

Swiss ordinances reach funds and economic resources owned or controlled by listed persons, with the operative wording taken from the EU instrument where the ordinance implements an EU package. Because adoption is autonomous and ordinance-by-ordinance, the test is read from the specific ordinance rather than assumed from the EU text.

US

The 50 Percent Rule — aggregated, automatic, and with no control test in the rule

OFAC's published guidance: an entity owned 50 percent or more, directly or indirectly, in the aggregate by one or more blocked persons is itself blocked, whether or not OFAC has ever named it. The consequence is that the SDN List is not a complete list of blocked parties. OFAC separately warns that entities controlled but not majority-owned by blocked persons carry real risk and may themselves be designated — but that is a warning, not the rule.

Where they diverge

The US rule is arithmetic and aggregating: 50 percent or more, directly or indirectly, held by one or more blocked persons **added together**, and the entity is blocked automatically whether or not it appears on any list — with no control test in the rule itself. The EU and UK tests are ownership **or** control, so a 30 percent holder who can direct the company's affairs can bring it in scope even though the arithmetic says no. Run a structure through both and you can get opposite answers: a company 25 percent owned by each of two blocked persons is blocked under the US aggregation rule; the same company may fall outside an EU or UK freeze unless control is made out.

2026-08-24 — checked against SI 2019/855 reg. 7, the Council's EU Best Practices paper, and OFAC's published 50 Percent Rule guidance.

05 · How does a permitted payment get through?

Licences, derogations and authorisations

A freeze is not a confiscation. Salaries, legal fees, insurance, humanitarian supplies and basic living costs move under licence. Which authority grants it, and how many of them there are, is a structural fact about the regime.

UN

Exemptions granted or notified through the Sanctions Committee

The UN framework provides for exemptions — basic expenses, extraordinary expenses, judgments and liens — operated through notification to or approval by the relevant Committee, and given effect through national procedures.

EU

Derogations granted by the competent authority of each member state

The Regulation itself sets out the derogation grounds; the decision is taken by the national competent authority, whose contact details are annexed to the Regulation. There is no EU-wide general licence of the UK or US kind, and practice between authorities is not uniform.

UK

OFSI general licences and specific licences, on statutory grounds

OFSI issues general licences that any person meeting the stated conditions may use without applying, subject to reporting and record-keeping conditions, and grants specific licences on application. The permissible grounds are set out in the schedule to the relevant regulations.

CH

SECO authorisations under the relevant ordinance

Each ordinance names SECO as the authority that may authorise payments and releases on stated grounds, in consultation with the other federal offices concerned. Applications go to SECO directly.

US

OFAC general licences (self-executing) and specific licences on application

General licences are published in the regulations or issued as standalone authorisations and authorise a described class of transaction without application. Anything outside one requires a specific licence applied for through OFAC's licensing portal. Both are read strictly — a general licence authorises what it says and no more.

Where they diverge

One counter, or twenty-seven. The UK and the US each have a single licensing authority with published general licences that anyone meeting the conditions can rely on without applying. The EU has no central licensing body at all: derogations are granted by the competent authority of the relevant member state, listed in the annex to each Regulation, so the same transaction may need a different authority — and can meet a different answer — depending on where the funds sit.

2026-08-24 — checked against SAMLA 2018 and OFSI's published licensing guidance, the derogation articles of Regulation (EU) No 269/2014, the Swiss ordinance authorisation articles, and 31 C.F.R. ch. V.

06 · Who has to tell the authorities, and when?

Reporting duties

The freeze is a prohibition; the report is a positive duty. It can be breached without any payment being made — holding a frozen account and not reporting it is a separate offence in more than one of these regimes.

UN

State-level implementation reporting

Reporting under the UN framework runs between states and the Committees. Private-sector duties are created by the implementing regime.

EU

Duty on any person to supply information to the competent authority

The Regulation requires natural and legal persons to supply immediately to the competent authority of the member state where they reside or are located any information that would facilitate compliance — including accounts and amounts frozen — and to cooperate in verifying it. It is not limited to regulated firms.

UK

Relevant firms must inform OFSI as soon as practicable

A relevant firm that knows or has reasonable cause to suspect that a person is a designated person, or has committed a financial-sanctions offence, must inform OFSI as soon as practicable, stating the information on which the knowledge or suspicion is based and any frozen holdings. Failure to report is itself an offence.

CH

Report frozen assets to SECO without delay

Persons and institutions holding or managing assets covered by a freeze must report them to SECO immediately, and the Embargo Act carries a general duty to provide the supervisory authorities with the information and documents they need. The reporting article sits in each ordinance.

US

Prompt reports of blocked and rejected transactions, plus an annual return

Holders of blocked property report to OFAC when property is first blocked and when a transaction is rejected, and file an annual report of blocked property held. The reporting, procedures and penalties regulations set out the form and timing.

Where they diverge

The UK's duty is narrower in who it binds but sharper in what it demands: it falls on "relevant firms" — financial institutions and other regulated businesses — and bites as soon as the firm knows or has reasonable cause to suspect, whether or not it holds anything. The EU duty under the Regulation falls on any person, entity or body, and the US reporting obligation is an annual return of blocked property plus prompt reporting when property is first blocked or a transaction rejected.

2026-08-24 — checked against the information provisions of SI 2019/855 and OFSI guidance, Art. 8 of Regulation (EU) No 269/2014, the Embargo Act reporting article, and 31 C.F.R. ch. V.

07 · What happens if it goes wrong?

Enforcement standard and penalties

The mental state required for liability differs by regime and by the type of liability. Two of these regimes impose civil penalties on a firm that did not know and had no reasonable cause to suspect; the EU Regulation expressly excludes liability in that case.

UN

No direct enforcement against private parties

The Security Council monitors state implementation through its Committees and panels of experts. Penalties against a firm come from national law.

EU

Penalties set by each member state; a harmonised criminal floor since 2024

EU Regulations require member states to lay down effective, proportionate and dissuasive penalties, which historically produced wide variation. Directive (EU) 2024/1226 defines the criminal offences and penalty levels member states must provide for violations of Union restrictive measures, and set a transposition deadline for national law.

UK

OFSI monetary penalties on a strict-liability basis, plus criminal offences

OFSI may impose a civil monetary penalty where it is satisfied on the balance of probabilities that a prohibition was breached. The Economic Crime (Transparency and Enforcement) Act 2022 removed the requirement that the firm knew or had reasonable cause to suspect, with effect from 15 June 2022. Breaches are separately criminal offences under the regulations, prosecuted to the criminal standard.

CH

Criminal liability under the Embargo Act

The Embargo Act makes wilful violation of a sanctions ordinance an offence, with a lesser penalty for negligence, and provides for prosecution under Swiss administrative criminal procedure. Enforcement runs through SECO and the federal department concerned rather than a civil penalty regime of the OFSI kind.

US

Strict-liability civil penalties; criminal liability for wilful violations

IEEPA provides civil penalties that OFAC may impose without proof of intent, and criminal penalties for wilful violations. OFAC's published enforcement guidelines set out the aggravating and mitigating factors, and the base-penalty structure that makes voluntary self-disclosure and a functioning compliance programme worth real money.

Where they diverge

Strict liability is the headline. Since 15 June 2022 OFSI may impose a monetary penalty without needing to show that the firm knew or had reasonable cause to suspect it was breaching a prohibition; the US civil penalty regime under IEEPA has long operated on the same strict basis, with criminal liability reserved for wilful violations. The EU, by contrast, had no harmonised criminal standard at all until Directive (EU) 2024/1226 required member states to criminalise defined violations — so historic EU enforcement variation between member states is a feature of the old architecture, not an anomaly.

2026-08-24 — checked against the Policing and Crime Act 2017 as amended by the Economic Crime (Transparency and Enforcement) Act 2022, Directive (EU) 2024/1226, the Embargo Act penal provisions, and IEEPA.

08 · Why do the four lists never quite agree?

Transposition, divergence, and the conflict the Blocking Statute creates

A designation does not appear in every regime at once, and sometimes appears in only one. The gaps are structural rather than administrative. In one case two regimes give contradictory instructions on the same facts.

UN

The apex — and the source of the de-listing problem

Most EU, UK and Swiss designations in the counter-terrorism and country regimes originate in a UN listing. Because the listing decision is taken by a political body, challenge routes were built afterwards: a Focal Point for de-listing requests, and an Ombudsperson for the ISIL/Al-Qaida list.

EU

Implements UN listings — but subject to fundamental-rights review, and blocks certain US measures

The Court of Justice held in Kadi that an EU regulation implementing a UN listing remains subject to review for compliance with fundamental rights under EU law: the UN origin of a listing does not immunise the EU act. Separately, the Blocking Statute prohibits EU operators from complying with the specified US extraterritorial measures listed in its annex.

UK

Autonomous since Brexit — retained regimes now diverge from the EU's

UK regimes were carried over as EU-exit statutory instruments and have been amended independently since. The UK list and the EU list overlap heavily but are not the same list, and designations, delistings and licence positions move on separate timetables. Screening against one does not discharge the other.

CH

Adopts EU packages by autonomous decision — which can mean a lag, and can mean differences

Switzerland implements UN measures as a UN member; EU measures reach Swiss law only when the Federal Council decides to adopt them, package by package. The decision is Switzerland's own, so the timing and occasionally the content differ from the EU instrument being mirrored. Read the ordinance, never the EU regulation it resembles.

US

Secondary sanctions — designating non-US parties with no US nexus at all

Beyond the primary regime, several US programmes provide for designating a non-US person for engaging in significant transactions with sanctioned parties. No US touchpoint is required. The practical effect on a European bank is that the decisive question is not only "am I a US person" but "what does dealing here cost me in access to the dollar system" — which is why US measures shape behaviour well outside US jurisdiction.

Where they diverge

The EU Blocking Statute is the case where the regimes conflict rather than differ: it prohibits EU operators from complying with the US extraterritorial measures listed in its annex, so an EU subsidiary of a US group can face a US penalty for acting and an EU penalty for not acting.

2026-08-24 — checked against Regulation (EC) No 2271/96, the Kadi judgment (Joined Cases C-402/05 P and C-415/05 P), and the UN de-listing procedures.

Related surfaces:

The walkthroughThe exercisesRegulatory WatchThe AtlasGlossary

The official sources

Free and authoritative, published by the administering bodies themselves. Each is a finding aid or a body of guidance; the law is in the instruments cited throughout this page.

OFSI Financial Sanctions Guidance

HM Treasury

UK Office of Financial Sanctions Implementation guidance on sanctions compliance.

EU Sanctions Map

European Commission

Interactive map of all EU restrictive measures currently in force.

SECO Sanctions List

SECO

Swiss State Secretariat for Economic Affairs sanctions and embargoes.

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