Sanctioning authorities
The agencies that impose, licence and enforce sanctions: what each one publishes, what powers it holds, and how its legal tests differ from the others.
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The most consequential differences between these authorities are not political but definitional. Whether a regime catches entities that are owned or entities that are owned or controlled decides whether a whole class of structures is caught, and the answer is not the same in Washington, London and Brussels.
- BIS: the Bureau of Industry and Security The US Commerce Department bureau that administers export controls on dual-use items, maintains the Entity List, and enforces the Export Administration Regulations.
- DFAT: the Australian Department of Foreign Affairs and Trade The Australian department administering autonomous and UN sanctions, maintaining the Consolidated List and issuing permits.
- EU sanctions: the Council, the Commission and member state authorities The EU adopts sanctions by Council decision and regulation; national competent authorities in each member state implement, licence and enforce them.
- Global Affairs Canada The Canadian department responsible for sanctions under the Special Economic Measures Act and related statutes, publishing consolidated lists and administering permits.
- OFAC: the Office of Foreign Assets Control The US Treasury office that administers and enforces most US economic sanctions, publishes the SDN List, issues licences and imposes civil monetary penalties.
- OFSI: the Office of Financial Sanctions Implementation The UK Treasury office that implements financial sanctions, maintains the UK consolidated list, issues licences and imposes monetary penalties.
- SECO: the Swiss State Secretariat for Economic Affairs The Swiss authority implementing sanctions under the Embargo Act, maintaining the searchable sanctions list and administering exemptions.
- UN sanctions: the Security Council and its committees The Security Council imposes sanctions by resolution; sanctions committees maintain the lists and Panels of Experts monitor and report on implementation.