Sanctions Evasion Reference

Designation

The formal act of adding a person, entity, vessel or aircraft to a sanctions list, which triggers the restrictions attached to that programme.

also known as

listing

reviewed

2026-08-20

A designation is an administrative decision, published in a legal notice, that names a target and states the authority under which it is listed. In the United States it takes effect on publication in the Federal Register and simultaneous addition to the relevant OFAC list; in the EU it follows a Council decision and regulation; at the UN it follows a Security Council committee listing.

A designation entry is a structured record, not a sentence of prose. It carries the primary name, any aliases the authority is aware of, addresses, dates and places of birth or incorporation, identity document numbers, and the programme tag under which the listing was made. Those identifiers are what screening systems actually match against, which is why so much evasion effort goes into making a counterparty look like a name that is not on the list.

Where this term is used

  • What is a front company? — A front company is a business that trades normally but exists largely to hide another party's involvement in its transactions. The real activity is the cover; the concealed party is the point.
  • How is cryptocurrency used to evade sanctions? — Settling obligations in virtual assets so that value moves without a correspondent bank, a payment message or a screening system in the path, and without any institution able to block it in transit.
  • What is ownership threshold structuring? — Arranging shareholdings so that designated parties own less than the percentage at which ownership is automatically attributed, while control of the entity stays where it was.

Related terms

  • Specially Designated Nationals and Blocked Persons List — The principal United States sanctions list. Property of anyone on it is blocked and US persons are generally prohibited from dealing with them.
  • Blocking — Freezing property and interests in property of a designated person that come within a jurisdiction, so it cannot be transferred, paid, withdrawn or otherwise dealt in.
  • Screening — Automated comparison of names, identifiers and other transaction data against sanctions lists and internal watchlists, at onboarding and on each payment.
  • Designations feed — A rolling, machine-readable record of additions to and removals from sanctions lists, published by the issuing authority and republished by aggregators.

Sources

  1. Recent Actions. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.
  2. Specially Designated Nationals and Blocked Persons List (SDN.XML). OFAC Sanctions List Service, 2026.

All glossary terms