Targeted Sanctions

Overview

Targeted Sanctions are sanctions designed to restrict specified persons, entities, sectors, activities, or property rather than broadly prohibit most dealings with an entire country. Their operational purpose is to apply economic or financial pressure more selectively while limiting unintended effects on the wider population or lawful activity. They should be considered alongside Economic Sanctions. The relevant distinction is comprehensive sanctions, which can broadly restrict transactions with a jurisdiction or government subject to defined exceptions and licenses.

A typical workflow is as follows: Authorities define designation criteria or sectoral restrictions, identify targets, publish prohibitions and licenses, and update measures. Organizations screen parties, evaluate ownership and activity, and apply program-specific restrictions.

Core controls include accurate identity and ownership data, list updates, sector and instrument classification, transaction-purpose review, legal escalation, license management, and periodic rescreening.

In payment and crypto operations, A transaction may be restricted because one targeted person owns or benefits from an entity, or because the activity involves a targeted sector, debt, equity, service, or asset.

Evidence should include target record, program and criteria, ownership, sector, instrument or service, transaction details, jurisdictional nexus, decision, license, and report. The narrower design can create false confidence if controls look only for named parties and ignore ownership or activity-based restrictions.

They are used to apply economic or financial pressure more selectively while limiting unintended effects on the wider population or lawful activity.

Implementation of Targeted Sanctions should map sanctions designed to restrict specified persons, entities, sectors, activities, or property rather than broadly prohibit most dealings with an entire country to the applicable entity, product, customer, transaction, and jurisdictional scope. Evidence for sanctions designed to restrict specified persons, entities, and sectors should preserve the governing requirement, policy version, control execution, exception decision, owner, and review date. Material changes affecting the Targeted Sanctions context and sanctions designed to restrict specified persons, entities, and sectors should trigger reassessment instead of silent reuse of an outdated conclusion.