Sanctions: a Route Map for the Individual, the Bank and the Structure

A person enters the sanctions perimeter from one of five sides: their own name on a list, a payment stuck or frozen, a refusal by a bank, an ownership structure with a "toxic" circuit, the country in which a counterparty is registered. In law these are five different procedures, with different authorities, different deadlines and different forms of application. The cost of choosing the wrong one is measured in months: a delisting petition will not release a frozen payment, and a licence for a transaction will not reopen a closed account.

This map answers not the question of whether sanctions are lawful, but the question of which procedure applies and in what order it is worked through. The five sections below are five entry points, and the reader takes exactly one; the table turns a task into a page, a rule and a figure. The substantive argument — the grounds for a listing, the control tests, the penalty formulas, the withholding rates — lives in the child articles.

The pattern running through the cluster matters more than any single procedure: a restriction almost never arrives alone. A listing drags a bank refusal behind it, the refusal turns the conversation to the origin of the money, and the source-of-funds question outlives the removal of the restriction itself by years. That is why the sequence of steps weighs more than the choice of jurisdiction.

Route 1. A name on the list

The first question is which measure has been applied. A blocking sanction strikes the person: property in which they hold an interest is taken out of circulation in its entirety. A sectoral measure prohibits a type of transaction, good or service, and the person concerned need not appear on any list at all — such a payment is not blocked but rejected and returned to the sender. The address to which an application goes and the substance of what is asked for both follow from that distinction.

The removal procedure is set out in OFAC sanctions removal: a petition for administrative reconsideration under 31 CFR 501.807, two permissible grounds — an insufficient basis for the listing, or circumstances that have since fallen away — remedial steps in the annex, and a review period running from one to three years. The review mechanics in other jurisdictions are set out in sanctions screening: OFAC checks a petition for completeness in 7–10 business days and usually issues its questionnaire within 90 days; in the EU a listing is reviewed periodically and challenged before the General Court, in the United Kingdom it is a ministerial review subject to judicial review. The Russian mirror circuit is built differently: in the list of unfriendly states the trigger is not a name but a jurisdiction. For an applicant to an investment programme, a listing and any connection to a listed person form a test of their own: investment migration for Russian applicants.

Route 2. The assets are frozen

A freeze does not transfer title: the asset remains yours, disposal is excluded, and the measure has no expiry — it lasts until delisting or until a licence. Confiscation is a separate act resting on a separate legal basis, and conflating the two regimes produces the wrong application.

The difference between the models is drawn in sanctions screening: American blocking moves the money into a separate interest-bearing blocked account and forbids its return to the sender; the European and British freeze leaves the funds where they sit, the account remains the client's account, interest accrues, and voting rights attaching to shares are frozen in full under the European Commission's FAQ as revised in May 2026. The licensing regime — general licences, which operate for everyone who meets their conditions, and specific licences, issued on application — is analysed in OFAC: review takes 18 months on average, a refusal is issued without reasons, and a licence is politically reversible — the one granted to Dan Gertler on 15 January 2021 was revoked on 8 March of the same year. The scale of licensing is visible from OFSI's 2024–2025 review: 904 decisions on specific licences and 19 general licences (screening). Where what is blocked is not a payment but a thing — a painting, a watch, a car — the goods regime takes over: the list of goods under EU sanctions.

Route 3. The bank has refused

A refusal on sanctions grounds looks to the client like a freeze, but it lives under a different law. The rule prohibits a specific set of services to specific categories of person; everything beyond that is the bank's own risk policy, a contractual decision that cannot be appealed on sanctions grounds.

The boundary is drawn in sanctions screening: Article 5b of Regulation 833/2014 prohibits deposits above EUR 100,000 per institution, crypto services, the issuance of payment instruments and acquiring for Russian nationals, residents and legal entities — and carves out nationals of the EU, the EEA and Switzerland together with holders of a residence permit; the European Commission's FAQ of 13 March 2026 confirmed that online banking, transfers and cash withdrawals fall outside the restriction, and that existing cards are not cancelled, although reissuing one counts as a fresh issuance. The same page sets out the mechanics of a false positive: on ECB figures, between 3% and 15% of payments end up as alerts requiring manual review, and the £160,000 penalty imposed on Bank of Scotland arose from an unrecognised spelling variant of a name. When an account is reopened it is the file that decides, not the passport: source of funds sets the composition of the dossier, AML/KYC for private clients the procedure on the bank's side, and a personal account abroad together with banks by jurisdiction show where to take it. Separate circuits of their own: the banks of China — a more conservative filter outside dollar settlement, neobanks — the licences of that segment, private banking — the entry threshold.

Route 4. The structure

Sanctions risk attaches not to a company's name but to ownership and control. The arithmetic of a shareholding no longer closes the question, and both halves of the test are assembled in sanctions screening: the Council of the EU's Best Practices (ST 11623/2024) introduce aggregation of holdings — 30% held by one designated person and 25% by another already amount to ownership — along with eight criteria of control, any one of which suffices; OFAC's guidance on sham transactions of 31 March 2026 adds seven indicators, among them a transfer to a relative close to the date of designation and a continuing role for the former owner. A formal change of nominee reads here as an indicator rather than a solution; the conceptual groundwork is in beneficial ownership and nominee structures.

Secondary sanctions move the risk onto the counterparty: after a designation under E.O. 14024, a foreign financial institution comes within reach of E.O. 14114 — closure of its correspondent account or full blocking for facilitating significant transactions. It is under no formal obligation; it faces the threat of losing access to the dollar, which is stronger than an obligation. What does assemble into a working construction is shown in sanctions-resilient structures: four layers — banking access, contractual mechanics, substance, compliance posture — and the rule that management, staff and records sit in the same hub that banks the structure. The presence requirements are in economic substance, the choice of intermediate vehicle in holding structures, the family circuit in the family office. Transparency is not optional here: what the tax authorities see irrespective of sanctions status is in CRS and tax transparency.

Route 5. The country perimeter

The fifth entry point is for those who appear on no list themselves but whose calculation is changed by the status of a country. Russia's list of unfriendly states was approved by Government Directive No. 430-r of 5 March 2022 and works as an operating filter: the sale of a Russian asset to a person from the list goes through the Government Commission, where the benchmark since October 2024 has been a discount of no less than 60% to the valuation plus a contribution of 35% of the price, transactions above RUB 50bn require presidential approval, and obligations to such creditors exceeding RUB 10m a month are discharged in roubles through a type "C" account.

The tax layer of the same status is the suspension of the double tax treaties: Decree No. 585 of 8 August 2023 froze the distributive articles of the treaties with 38 states (confirmed by Federal Law No. 598-FZ of 19 December 2023); payments now run at domestic rates — 15% on dividends and 25% on interest and royalties from 1 January 2025, against 20% before — while the United States responded in mirror image from 16 August 2024, leaving Article 22 on relief for double taxation untouched. The other side of the map is where the network is shifting: the UAE is not on the Decree 585 list, so the suspension does not reach it, and the new Russia–UAE Agreement for the Elimination of Double Taxation with respect to Taxes on Income and on Capital of 17 February 2025 (Federal Law No. 189-FZ of 7 July 2025, in force since 18 July 2025) applies in full from 1 January 2026 — withholding capped at 10% on dividends, interest and royalties where the recipient is the beneficial owner (the UAE); Hong Kong does not appear on the decree's list, while Singapore sits on it at item 36 (Hong Kong). The EU goods perimeter is set by the list of goods under EU sanctions: Article 3h and Annex XVIII with a threshold of EUR 300 per unit, Article 3k and Annex XXIII with almost no thresholds; the control point is the CN code on the declaration, not the name of the item. The personal perimeter is closed by relocation from Russia — the choice of base, loss of Russian tax residency — the mechanics of exit, and Kazakhstan and China — the payment routes.

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