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Sanctions Glossary


The United States Department of Commerce's Bureau of Industry and Security


The act of adding a person (individual, entity, vessel, or plane) to a sanctions list entails different ramifications based on the type of the list to which a person is added. If the list is a blocking/asset-freezing list, then all the assets of the added person are subject to blocking sanctions.


Export Administration Regulations


Financial Crime Enforcement Network is an agency of the U.S. Government, part of the Treasury, which is in charge of collecting and analyzing information about financial transactions in order to combat domestic and international money laundering, terrorist financing, and other financial crimes.

Financial Services

The term financial services, in general, includes loans, transfers, accounts, insurance, investments, securities, guarantees, foreign exchange, letters of credit, and commodity futures or options.

Foreign Financial Institution (under OFAC sanctions)

Any foreign entity that is engaged in the business of accepting deposits; making, granting, transferring, holding, or brokering loans or credits; purchasing or selling foreign exchange, securities, futures or options; or procuring purchasers and sellers thereof, as principal or agent.
It includes depository institutions; banks; savings banks; money services businesses; operators of credit card systems; trust companies; insurance companies; securities brokers and dealers; futures and options brokers and dealers; forward contract and foreign exchange merchants; securities and commodities exchanges; clearing corporations; investment companies; employee benefit plans; dealers in precious metals, stones, or jewels; and holding companies, affiliates, or subsidiaries of any of the foregoing.

General License

A general license is is an authorization from OFAC to engage in a transaction that otherwise would be prohibited to a particular type of transaction for a class of persons without the need to apply for a license.


International Emergency Economic Powers Act (1977) is piece of federal law authorizing the president to regulate international commerce after declaring a national emergency in response to any unusual and extraordinary threat to the United States which has its source in whole or substantial part outside the United States.


The term knowingly, with respect to conduct, a circumstance, or a result, means that a person has actual knowledge, or should have known, of the conduct, the circumstance, or the result.


Office of Foreign Assets Controls is an agency of the U.S. Government and part of the Treasury which administers and oversees the United States sanction programs.

OFAC 50% Rule

If one or several SDNs own 50% (or more) of an entity (directly or indirectly, individually or in aggregate), then that entity is also blocked by the operation of law.


The Office of Financial Sanctions Implementation. OFSI is a part of HM Treasury is the office in charge of the administration of the UK's financial sanctions.

Primary Sanctions

Sanctions restrictions that apply to a person (individual or entity) over whom the sanctions-imposing authority has jurisdiction. For example, the prohibition on provision of services to Iran by a U.S. person.

SDN List

The Specially Designated Nationals list. It is a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific.

SSI List

The Sectoral Sanctions Identifications List. it is a list to identify persons operating in sectors of the Russian economy identified by the Secretary of the Treasury pursuant to Executive Order 13662.

Sanctions Screening

Sanctions screening is a control used in the detection, prevention and disruption of financial crime and,
in particular, sanctions risk. It is the comparison of one string of text against another to detect
similarities which would suggest a possible match. It compares data sourced from a financial institution's operations, such as customer and transactional records, against lists of names and other indicators of sanctioned parties or locations.

Secondary Sanctions

Secondary sanction is a commonly used phrase to describe the possibility of imposition of sanctions on a target over whom a sanctions-imposing authority has no-jurisdiction. Secondary sanctions restrictions can vary from being designated to less aggressive measures like procurement sanctions. Secondary sanctions are attached to a primary sanction target and intend to deter the person over whom a sanctions-imposing authority have no jurisdiction from engaging in an activity that was targeted by the primary sanction restriction. Secondary sanctions are a construct under the U.S. sanctions.

Sectoral Sanctions

Sectoral sanctions are debt/equity restrictions that are imposed against certain sectors of a country's economy. Sectoral sanctions were first introduced in the aftermath of Russia's invasion of Crimea in 2014. They were later used by the United States in the Venezuela program.


It is a term of art. OFAC has published a number of FAQs to explain what are the criteria for a transaction to be considered as significant. OFAC may consider many factors including, but not limited to: size, number, and frequency; type, complexity and commercial purpose; the level of awareness or involvement by the bank’s management; whether the activity or payment illustrates a pattern of practice or is an isolated event; the ultimate economic benefit conferred upon the designated person(s); and whether the transactions involved the use of deceptive financial practices to obscure the identities of the parties involved.

Specific License

A specific license is a written document issued by OFAC to a particular person or entity, authorizing a particular transaction in response to a written license application.

Trade Sanctions

Trade Sanctions is a phrase used to describe the restrictions on the flow of goods or services as opposed to financial sanctions that are restrictions on the financial flows and freezing of assts.

U.S. Person

U.S. citizens and permanent resident aliens (Green Card holders) regardless of where they are located, all persons and entities within the United States, all U.S. incorporated entities and their foreign branches.
In the cases of certain programs, foreign subsidiaries owned or controlled by U.S. companies also must comply.

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