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.
L0 Explain simply
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.
L1 Core concepts
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.
L2 Practitioner view
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.
L3 Technical details
Each issuer publishes machine-readable list files with its own structure and identifiers. The UN consolidated list carries a permanent reference number whose prefix encodes the regime, and UN designations flow into EU and UK law through implementing acts, so the same person can appear on several lists with different record formats. OFAC publishes the SDN List alongside other, non-SDN lists whose legal consequences differ — a name on a sectoral or non-blocking list does not carry the same obligations as an SDN entry, which is why the source list of a hit matters, not just the name. Screening systems therefore preserve which authority and which list each record came from, and investigators read the programme tag on a match before deciding what the hit would even mean.
Sources & standards2
- Official requirement
United Nations Security Council Consolidated List ↗ — United Nations Security Council · Consolidated list structure and permanent reference numbers
Published in XML, HTML, and PDF formats and updated as committees act; each name is subject to the measures of its specific sanctions committee, not one uniform regime.
- Official requirement
Specially Designated Nationals and Blocked Persons List (SDN List) ↗ — US Department of the Treasury, Office of Foreign Assets Control · SDN List and related non-SDN list distinctions
Updated continuously; machine-readable formats are distributed via OFAC's Sanctions List Service. Every list entry appearing in this site's examples is fictional.
Sources for this topic5
- Official requirement
United Nations Security Council Consolidated List ↗ — United Nations Security Council · United Nations Security Council Consolidated List
Published in XML, HTML, and PDF formats and updated as committees act; each name is subject to the measures of its specific sanctions committee, not one uniform regime.
- Official requirement
Specially Designated Nationals and Blocked Persons List (SDN List) ↗ — US Department of the Treasury, Office of Foreign Assets Control · Specially Designated Nationals and Blocked Persons List
Updated continuously; machine-readable formats are distributed via OFAC's Sanctions List Service. Every list entry appearing in this site's examples is fictional.
- Official requirement
Consolidated list of persons, groups and entities subject to EU financial sanctions ↗ — European Commission · EU consolidated list of persons, groups and entities subject to financial sanctions
Covers only financial sanctions consisting of asset freezes; the EU Sanctions Map (sanctionsmap.eu) documents the broader restrictive-measure regimes.
- Official requirement
UK financial sanctions general guidance ↗ — Office of Financial Sanctions Implementation, HM Treasury · UK financial sanctions guidance and the UK consolidated list
General in nature; regime-specific guidance and the underlying UK regulations take precedence over it.
- Simplified educational illustration
Payments Signal editorial teaching models — Payments Signal
What this simplifies: The four-issuer model omits other national authorities and list types (for example export-control and non-proliferation lists) that some institutions also screen. The banned-driver analogy simplifies how UN measures are transposed into national law. All banks named in examples are fictional.
Used wherever diagrams, scenarios, figures, or example values are didactic constructions rather than sourced facts; every such use carries a simplifications disclosure. All people, companies, banks, and list entries in examples are fictional.
Deepest material on this page: L3 — Technical details. Where a topic stops short of implementation depth, that is a deliberate coverage decision, not an oversight — see coverage.