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Seven guided pages covering what sanctions are, how designations work, who enforces them, and how evasion is actually detected — in the order that makes the rest of the site legible.
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These pages are written to be read in order, and they assume nothing. If you have arrived from a news story and want to know what any of it means, this is the shortest route.
If you already know the basics, the two worth reading anyway are the 50 percent rule, because the US, UK and EU tests differ in a way that is widely misreported, and how evasion is detected, which explains the method behind every technique page on this site.
- What are sanctions and how do they actually work? Sanctions are legal restrictions on dealings with a named person, entity, sector or country, imposed by a state or international body and enforced against anyone within that authority's jurisdiction.
- How does someone get on a sanctions list? A designation is a published administrative decision naming a target and stating the authority for listing it, which triggers the restrictions attached to that programme from the moment of publication.
- What is the 50 percent rule, and why is it different in the UK and EU? OFAC treats any entity owned fifty per cent or more in aggregate by blocked persons as itself blocked, whether or not it is named. UK and EU measures instead catch entities owned or controlled.
- What are secondary sanctions? Secondary sanctions threaten non-US persons with loss of access to the US market or financial system for conduct that is lawful where it happens, rather than prohibiting that conduct directly.
- Which agencies actually investigate and penalise sanctions violations? Financial sanctions are enforced by treasury agencies such as OFAC and OFSI, export controls by agencies such as BIS, and criminal conduct by prosecutors, frequently all three in parallel.
- How do investigators actually find sanctions evasion? Almost always by reconciling records held by different parties. Individual documents in an evasion scheme are internally consistent; what fails is the comparison between them.
- What is the difference between sanctions and export controls? Sanctions restrict dealings with a party; export controls restrict the movement of an item by reference to what it is, where it is going and what it will be used for. Screening a counterparty satisfies neither obligation for the other.