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13 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.
- What is a general licence versus a specific one? A general licence lets anyone meeting its conditions do something sanctions would otherwise prohibit, without applying. A specific licence is granted to one applicant for one transaction. General licences carry conditions, and breaching them is its own violation.
- How does someone get removed from a sanctions list? Delisting is an administrative petition to the authority that listed you. In the US the regulations set out what to submit and promise a written decision; they do not promise a timeline or a meeting.
- How does the Russian oil price cap work? The price cap lets service providers carry Russian oil only if it was bought at or below a set price. Because they cannot see the price, the US relies on recordkeeping, attestations and a safe harbour.
- How are sanctions penalties calculated? Both OFAC and OFSI start from a base figure tied to the seriousness of the case, then reduce it for self-disclosure and cooperation and raise it for wilfulness. Reading the method explains why two similar breaches can end very differently.
- How do US sanctions reach companies outside the United States? A company with no US office can still be liable if a payment clears through a US bank, it is owned by a US person, or it handles US-origin goods. These are direct violations, not secondary sanctions.
- Why does sanctions screening miss things? Seven recurring places where a check fails: a stale list, a name that does not match, ownership the list lacks, an alert answered wrongly, a check that ran once, a system outside the check, and a control nobody retested.