Who imposes sanctions
The UN, the US, the EU, and the UK each run their own sanctions lists — overlapping but not identical — and a bank may owe obedience to several at once.
IN ONE LINE
An everyday analogy: imagine a road network where four different authorities can each declare a driver banned — a global council, and three national or regional regulators.
Their banned-driver registers overlap heavily but are not copies of each other: one authority may ban a driver the others have not, and updates arrive on different days.
A courier company operating across borders has to honour every register that applies where it drives, holds a licence, or handles that authority's currency.
Banks are in the courier's position: they screen against the lists of every authority whose law reaches them, not just the one at home.
Knowing who issues each list is the first step in knowing which ones you must obey.
WHAT IT ACTUALLY IS
Four issuers dominate sanctions screening.
The United Nations Security Council adopts sanctions that all member states must implement; its consolidated list is the global baseline, but it binds banks only through national or regional law.
The United States Office of Foreign Assets Control (OFAC) administers US programmes and publishes the SDN List among others; its reach is felt worldwide because so many payments settle in US dollars.
The European Union adopts restrictive measures published in a consolidated list that applies across member states.
The United Kingdom's Office of Financial Sanctions Implementation (OFSI) maintains the UK consolidated list.
The lists overlap heavily but diverge in coverage and timing — a name can appear on one for days before another, or never appear at all.
HOW IT WORKS
Which lists a bank screens against is decided by exposure, not preference.
A bank screens the lists of every jurisdiction where it is incorporated, licensed, or operating; the currencies it clears — US dollar business effectively imports US expectations even for non-US banks — and what its correspondents demand as a condition of the relationship.
A euro-area bank with a dollar clearing account will typically screen EU, UN, and US lists at minimum, plus UK lists if it does UK business.
Divergence between lists is an operational fact: since the UK left the EU its designations are made independently, so EU and UK lists must be treated as separate obligations even where they overlap.
List selection is documented policy, reviewed as the bank's footprint changes.
THE WORDS
- OFAC
- The US Treasury office that administers and enforces US economic sanctions programmes, including the SDN List.
- UN Security Council
- The United Nations body whose sanctions resolutions bind all member states, which implement them through their own domestic laws and lists.
- OFSI
- The UK Treasury unit that implements and enforces financial sanctions in the United Kingdom and maintains the UK's list of asset-freeze targets.
- Sanctions list
- A published register of the persons, entities, and other targets designated under a sanctions regime, used as reference data for screening.
READ FIRST
CONNECTED TO
SOURCES
- United Nations Security Council Consolidated List — United Nations Security Council
- Specially Designated Nationals and Blocked Persons List (SDN List) — US Department of the Treasury, Office of Foreign Assets Control
- Consolidated list of persons, groups and entities subject to EU financial sanctions — European Commission
- UK financial sanctions general guidance — Office of Financial Sanctions Implementation, HM Treasury
- Payments Signal editorial teaching models — Payments Signal
Derived from Who imposes sanctions. Every claim on this card is sourced on that page.