Sanctions Evasion Reference

Sectoral sanctions

Restrictions on particular types of dealing with named entities in a defined economic sector, rather than a full block on all dealings with them.

reviewed

2026-08-20

Sectoral measures prohibit specific activities, most often new debt above a stated maturity, new equity, or the supply of particular goods and services, while leaving other business with the same entity lawful. They are used where a full block would cause disproportionate collateral damage.

The consequence for detection is that the question stops being “is this counterparty listed” and becomes “is this particular transaction, of this tenor, in this sector, prohibited”. That is a harder question to automate, and structuring around a maturity limit or a service definition is a recognised evasion pattern.

Where this term is used

  • How is correspondent banking used to evade sanctions? — Using a chain of banks that each know only their own customer, so that a payment for a restricted party reaches a currency it could not access directly, without any bank in the chain seeing the whole transaction.
  • What is a professional enabler? — A lawyer, accountant, formation agent or broker whose services are what makes a concealment structure work, and whose repeated involvement across unconnected clients is itself the evidence.
  • What are third-country bank accounts and how are they used? — Holding accounts in a jurisdiction unconnected to the restricted party, the goods or the contract, so that payments reach and leave the restricted economy without ever appearing to touch it.

Related terms

  • Sanctions — Restrictions imposed by a state or international body on dealings with a named person, entity, sector or country, enforced against anyone within that authority's jurisdiction.
  • Designation — The formal act of adding a person, entity, vessel or aircraft to a sanctions list, which triggers the restrictions attached to that programme.
  • General licence — A published authorisation permitting a defined category of otherwise prohibited transactions, available to anyone who meets its terms without applying.

Sources

  1. Sanctions Programs and Country Information. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.

All glossary terms