Sanctions

Numerous varieties of sanctions or restrictions are currently enacted against certain nations, predominantly due to the political climate of the penalized country.

While some sanctions are expansive, covering countries such as Iran, others are more targeted, possibly focusing on an arms embargo or specifically addressing a deposed despot along with their relatives and close associates.

Navigating the complexities of sanctions is a challenging aspect of risk management, particularly in identifying the specifics of a given sanction’s regime.

The primary organisations imposing sanctions are the United Nations, the European Union, and the Office of Foreign Assets Control in the United States, also known as OFAC.

Their sanction lists vary, necessitating careful review of potential discrepancies, such as unilateral sanctions, an example being the United States’ sanctions on Cuba.

All UN countries are obligated to align with UN sanctions, with many also considering the EU and US as benchmarks for their own sanctions policies.

Regulated businesses should also be aware of a further complexity with OFAC sanctions as any US dollar transaction will cause that transaction to fall under US jurisdiction and, therefore, the US sanction regime, even if the said transaction or entities behind the transaction, have no direct contact with the United States.

As mentioned, many countries have developed their own sanction policies. For instance, post-Brexit, the United Kingdom sanction regime list, which, while largely mirroring the EU’s, exhibits certain distinctions.

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