Sanctions restrict dealings with listed people, entities and countries; export controls restrict where sensitive goods, software and technology may go. Each regime has its own reach: UK and EU sanctions bind persons in and nationals of those jurisdictions, US sanctions reach US persons and entities owned 50% or more by blocked persons, and UN listings must be implemented in the UAE within 24 hours. Groups need screening, ownership analysis and licensing processes that work across all of them.
Who enforces what
In the UK, the Office of Financial Sanctions Implementation in HM Treasury implements and enforces financial sanctions, while trade sanctions licences come from the Office of Trade Sanctions Implementation or the Export Control Joint Unit; without an exception, any prohibited activity needs a licence. In the US, OFAC administers and enforces economic and trade sanctions, and under its 50 percent rule entities owned 50% or more in aggregate by blocked persons are treated as blocked even if not named. OFAC's enforcement guidelines treat a risk-based compliance programme as a factor in penalties, and voluntary self-disclosure halves the base penalty.
EU sanctions are implemented by Member States; in France, the Direction générale du Trésor receives asset-freeze declarations and reports of suspected circumvention. In the UAE, any person must freeze funds of persons on the UN Sanctions List or the UAE Local Terrorist List within 24 hours of listing, without prior notice.1234567
Export controls on dual-use goods and technology
Exporting dual-use items listed in Annex I to Regulation (EU) 2021/821 requires an authorisation in the EU. Great Britain has its own Strategic Export Control Lists, with Northern Ireland still applying the EU regulation. US export controls travel with the item: the Export Administration Regulations cover all items in the US, US-origin items anywhere, and some foreign-made items with controlled US content or made with US technology, so a non-US group can need a US licence to re-export.8910
| Jurisdiction | Authority or rule | Key point | Source |
|---|---|---|---|
| United Kingdom | OFSI (financial), OTSI and ECJU (trade) | Licence needed for prohibited activity unless an exception applies | GOV.UK |
| United States (federal) | OFAC | 50% rule: entities owned 50% or more by blocked persons are blocked | ofac.treasury.gov |
| United States (federal) | OFAC enforcement guidelines | Compliance programme is a penalty factor; self-disclosure halves base penalty | Cornell LII, 31 CFR 501 App. A |
| European Union / France | Member State authorities; Direction générale du Trésor | National authorities implement EU sanctions and receive freeze reports | tresor.economie.gouv.fr |
| UAE | Cabinet Decision No. 74 of 2020 | Freeze within 24 hours of UN or local listing | Ministry of Economy and Tourism |
| European Union | Regulation (EU) 2021/821 | Authorisation needed for Annex I dual-use exports | EUR-Lex |
| Great Britain | Strategic Export Control Lists | Licence for listed dual-use items | GOV.UK |
| United States (federal) | Export Administration Regulations | Apply to US-origin items wherever located | eCFR 15 CFR 734.3 |
Decisions to make
- Which sanctions regimes bind each group entity and its staff?1367UK, EU, US and UAE rules apply on different connecting factors, and a group can be bound by several at once.
- Do counterparties have owners who are listed, directly or indirectly?4Under OFAC's 50 percent rule an unlisted company can be blocked because of its owners.
- Are any products, software or technology listed, or of US origin?8910Listed dual-use exports need authorisation in the EU and Great Britain, and US-origin items carry EAR controls on re-export.
- Is there a documented compliance programme and a process for self-disclosure?5OFAC weighs the programme in penalties and halves the base penalty for voluntary self-disclosure.
Documents usually needed
- Sanctions and export control risk assessment and policy
- Screening records for customers, suppliers, agents and their owners
- Product classification matrix (EU, UK and US control list entries, EAR99 where relevant)
- Licences and records of use, with end-user statements
- Escalation and voluntary disclosure procedure
Common mistakes
- Screening only names on lists and not ownership of 50% or more by blocked persons
- Assuming US export controls do not apply outside the US to US-origin items
- Leaving UAE freeze obligations to banks when they apply to any person
- Classifying products once and not re-checking after list updates
- Treating a licence obtained in one jurisdiction as covering the same transaction under another regime
Questions businesses ask
Does a non-US company need to worry about OFAC?
Yes where US persons, US-origin items or US territory are involved, and its US subsidiaries are US persons. The 50 percent rule also affects whom any US person can deal with.3410
Who issues UK sanctions licences?
OFSI for financial sanctions; OTSI or the Export Control Joint Unit for trade sanctions.2
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- UN Security Council sanctions procedures were not researched directly; they are covered here through UAE implementation.
- EU rules on best efforts to ensure subsidiaries comply, and the EU equivalent of the ownership test, were not confirmed.
- German national sanctions and export control authorities (BAFA, Bundesbank) were not separately confirmed.
- Saudi, Indian and Singapore export control regimes are covered in the market guides, not compared here.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
The Office of Financial Sanctions Implementation, part of HM Treasury, implements and enforces UK financial sanctions, including the Russian oil price cap. Trade sanctions are handled separately.
UK financial sanctions licences are issued by the Office of Financial Sanctions Implementation (OFSI), and trade sanctions licences by the Office of Trade Sanctions Implementation (OTSI) or the Export Control Joint Unit; without an exception, any prohibited activity needs a licence. Transfers of funds to or through a designated person can engage both financial and trade sanctions.
The Office of Foreign Assets Control (OFAC), part of the US Treasury, administers and enforces US economic and trade sanctions, using asset blocking and trade restrictions against targeted countries, regimes and persons. Federal. Programmes include Russia-related, Iran, North Korea, Cuba, Venezuela-related, counter-narcotics and cyber-related sanctions.
Under OFAC's 50 percent rule, entities owned 50 percent or more in the aggregate, directly or indirectly, by one or more blocked persons are themselves treated as blocked, even if not named on the sanctions list. Federal; OFAC programmes. Indirect ownership through other entities counts. Control without majority ownership is not captured by the rule but can still create risk.
Only the question text and opening of FAQ 401 were visible on the index page; the full FAQ page could not yet be checked. The point on control is general knowledge, not from the page.
OFAC's Economic Sanctions Enforcement Guidelines treat the existence and adequacy of a risk-based OFAC compliance programme as a general factor in penalty decisions, and voluntary self-disclosure halves the base penalty amount. Federal. In non-egregious cases with self-disclosure the base is one half of the transaction value (subject to a cap); in egregious cases, one half of the statutory maximum.
Regulatory text read on the Cornell Legal Information Institute reproduction of the Code of Federal Regulations; the eCFR at ecfr.gov is the government version. The cap figure shown on the page may be out of date and is not repeated here.
The Direction générale du Trésor is the French contact point for implementing EU financial sanctions, receives declarations on asset freezes and suspected circumvention, and maintains the national register of asset freezes (registre national des gels). EU sanctions regulations apply directly to all natural and legal persons operating in the EU, to EU nationals wherever they are and to entities established under member-state law.
Any person in the UAE must freeze, without prior notice, funds owned or controlled by persons on the UN Sanctions List or the UAE Local Terrorist List within 24 hours of the listing decision. Applies to all persons in the UAE; financial institutions and designated non-financial businesses must also screen records and transactions (Article 21).
An authorisation is required to export dual-use items listed in Annex I to Regulation (EU) 2021/821. Dual-use items listed in Annex I.
A licence is needed to export dual-use items listed on the UK Strategic Export Control Lists from Great Britain; in Northern Ireland the EU Dual-Use Regulation (EU) 2021/821 applies instead. Licences include standard individual export licences and open general licences registered through SPIRE; the Export Control Joint Unit handles strategic export licensing queries. Moving controlled dual-use items from Northern Ireland to the EU or Great Britain needs no licence.
Items subject to the Export Administration Regulations include all items in the United States, all US-origin items wherever located, certain foreign-made items incorporating controlled US-origin content above de minimis levels and certain foreign-produced direct products, and items subject to the EAR but not listed on the Commerce Control List are designated EAR99. Federal, 15 CFR 734.3(a) and (c), administered by the Bureau of Industry and Security. Whether a licence is needed depends on the item's classification, destination, end user and end use. Defence articles under ITAR are outside this claim.
The eCFR is an authoritative but unofficial editorial compilation; the official text is the annual CFR edition and Federal Register.
Questions on this topic
10 statements on sanctions and export restrictions: the basics
