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Sanctions Resources

Reference material for people who work with sanctions: who the authorities are, and what the terms mean.

Sanctions authorities directory

The main bodies that make, apply and enforce sanctions and export controls.

JurisdictionAuthorityResponsibility
United StatesOffice of Foreign Assets Control (OFAC), Department of the TreasuryAdministers and enforces economic sanctions; maintains the SDN List; issues licences.
United StatesBureau of Industry and Security (BIS), Department of CommerceAdministers export controls under the Export Administration Regulations; maintains the Entity List.
United KingdomForeign, Commonwealth and Development Office (FCDO)Leads on sanctions policy and makes designations; maintains the UK Sanctions List.
United KingdomOffice of Financial Sanctions Implementation (OFSI), HM TreasuryImplements financial sanctions, issues licences and takes civil enforcement action.
United KingdomOffice of Trade Sanctions Implementation (OTSI), Department for Business and TradeCivil enforcement of trade sanctions.
European UnionCouncil of the European UnionAdopts restrictive measures by decision and regulation.
European UnionNational competent authorities of the member statesApply and enforce EU sanctions and grant authorisations.
United NationsSecurity Council and its sanctions committeesImpose sanctions binding on all member states and maintain the UN lists.
United Arab EmiratesExecutive Office for Control and Non-ProliferationCoordinates implementation of targeted financial sanctions.
SwitzerlandState Secretariat for Economic Affairs (SECO)Applies sanctions under the Embargo Act.
CanadaGlobal Affairs CanadaAdministers Canadian sanctions legislation and issues permits.
AustraliaAustralian Sanctions Office, Department of Foreign Affairs and TradeAdministers UN and autonomous sanctions and issues permits.
SingaporeMonetary Authority of SingaporeIssues regulations giving effect to sanctions for financial institutions.
JapanMinistry of Finance and Ministry of Economy, Trade and IndustryApply asset freezes and trade measures under the Foreign Exchange and Foreign Trade Act.

Sanctions glossary

AIS
Automatic Identification System: the transponder system that broadcasts a vessel's identity and position.
Asset freeze
A prohibition on dealing with the funds or economic resources of a designated person, and on making them available to that person.
Blocking statute
A law that forbids compliance with certain foreign sanctions within a jurisdiction.
Circumvention
Arranging a transaction so as to avoid the effect of a sanction while achieving the prohibited result.
Designation
The act of naming a person, entity or vessel as a target of sanctions.
Dual-use goods
Goods, software and technology that have both civil and military applications.
ECCN
Export Control Classification Number: the code that identifies an item on the US Commerce Control List.
Entity List
A list kept by BIS of parties to whom exports of controlled items require a licence.
50 Percent Rule
OFAC's rule that an entity owned 50 percent or more, in aggregate, by blocked persons is itself treated as blocked.
General licence
A licence that authorises a class of activity for anyone who meets its terms, without an application.
Ownership and control
The tests used to decide whether an unlisted company is caught because of its link to a designated person.
Price cap
A measure allowing services for seaborne oil of a given origin only where it is sold at or below a set price.
SDN List
OFAC's list of Specially Designated Nationals and Blocked Persons.
Secondary sanctions
Measures that expose non-US persons to penalties for dealings that have no US connection.
Shadow fleet
Vessels that carry sanctioned cargoes using opaque ownership and deceptive practices.
Ship-to-ship transfer
The transfer of cargo between vessels at sea, sometimes used to disguise its origin.
Specific licence
A licence granted to a named applicant for a particular transaction or activity.
Transshipment
Moving goods through an intermediate country or port on the way to their final destination.

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