Question 1

What are sanctions?

Accepted Answer

Sanctions are restrictive measures imposed by governments or international bodies (UN, EU) to influence the behaviour of states, entities or individuals — typically by freezing assets, restricting financial transactions, banning trade in specific goods, or prohibiting travel. They are a foreign-p...

Question 2

Who issues sanctions that businesses must screen against?

Accepted Answer

The major regimes a globally-operating business typically screens against are:

Question 3

What is the OFAC SDN List?

Accepted Answer

The Specially Designated Nationals and Blocked Persons List is the US Treasury's Office of Foreign Assets Control's master list of individuals, entities, vessels and aircraft whose assets are blocked and with whom US persons are generally prohibited from dealing. US persons (citizens, permanent r...

Question 4

What is the EU Consolidated Financial Sanctions List?

Accepted Answer

A consolidated electronic list maintained by the European Commission of all persons, groups and entities subject to EU financial sanctions under the Common Foreign and Security Policy (CFSP). Member State competent authorities enforce it. It is downloadable in XML and is the technical source used...

Question 5

What is the DFAT Consolidated List (Australia)?

Accepted Answer

The Department of Foreign Affairs and Trade Consolidated List is the master list of all persons and entities subject to Australian targeted financial sanctions and travel bans, combining UNSC-mandated designations and Australia's autonomous sanctions under the *Autonomous Sanctions Act 2011* and...

Question 6

What is the UK Sanctions List?

Accepted Answer

The OFSI-maintained consolidated list of persons designated under the *Sanctions and Anti-Money Laundering Act 2018* (SAMLA) and the various country-specific UK sanctions regulations enacted post-Brexit. It replaced the EU list for UK purposes after the end of the transition period (31 December 2...

Question 7

What is a sectoral sanction?

Accepted Answer

A sanction that prohibits specific *types* of dealings (e.g. financing beyond a certain maturity, transfers of certain technology) with otherwise non-blocked persons in defined sectors of a target country's economy. The clearest example is OFAC's Sectoral Sanctions Identifications (SSI) List targ...

Question 8

What is the difference between a sanctions list and a watchlist?

Accepted Answer

A sanctions list is legally binding: dealing with a listed party is a criminal offence. A watchlist is informational — examples include law enforcement most-wanted lists, regulatory enforcement actions, debarment lists (e.g. World Bank, ADB), and proprietary risk-intelligence databases. Watchlist...

Question 9

What is the 50% rule (OFAC)?

Accepted Answer

OFAC's Fifty Percent Rule treats any entity owned 50% or more, in aggregate, directly or indirectly, by one or more SDN-listed persons as itself blocked — even if the entity is not separately named on the SDN List. The same logic applies to other US blocking regimes. The EU applies an analogous "...

Question 10

Who must screen against sanctions lists?

Accepted Answer

Sanctions law applies broadly. In the US, all US persons and any transaction with a US nexus (USD clearing, US-origin goods, US person involvement). In the EU, all persons within EU territory and EU nationals worldwide. In the UK, all UK persons globally. In Australia, all persons in Australia an...

Question 11

How often should sanctions screening be re-run?

Accepted Answer

Two screening events are universal: at onboarding and at the time of each transaction. The customer base should also be rescreened against list updates, ideally within 24 hours of a list change. Major regulators (FinCEN, FCA, AUSTRAC) expect a documented, risk-based screening frequency. For highe...

Sanctions & watchlists