The Major Sanctions Authorities: UN, US (OFAC), EU, UK (OFSI)

This lecture is a map, and it's worth memorizing. Four bodies dominate the CGSS exam. The United Nations Security Council sets a global baseline.

The U.S. Office of Foreign Assets Control, OFAC, has the deepest practical reach because so much of the world clears in dollars.

The European Union imposes binding measures through Council Regulations. And the United Kingdom acts through its Office of Financial Sanctions Implementation, OFSI. Each one designates targets, publishes lists, and expects firms to screen against them.

Let's take them one at a time and, just as important, see how they connect.

Start at the top. The U.N.

Security Council can impose sanctions through resolutions under Chapter Seven of the Charter, and Article twenty-five binds member states to carry out the Council's decisions. Day to day, sanctions committees manage the specific listings and any exemptions. The Council maintains the U.

N. Consolidated List, which functions as a global floor: when the Council designates a target, member states are expected to implement that designation domestically. So a U.

N. listing isn't self-executing in your bank's screening system, it flows into national and regional law first. But it's the common starting point, which is why so many names appear on the U.

N., E.U.

, U.K., and U.

S. lists at once. The exam likes the idea that the U.

N. sets a baseline that others build on, and sometimes go beyond.

Now OFAC. It sits inside the U.S.

Department of the Treasury and administers and enforces U.S. sanctions.

Its reach is what makes it formidable. OFAC's rules bind U.S.

persons, transactions involving U.S.-origin goods or technology, and, crucially, transactions that clear through the U.

S. financial system, which catches an enormous share of global dollar payments. OFAC publishes the Specially Designated Nationals list, the S-D-N List, of blocked persons, plus a separate Consolidated List for non-S-D-N programs like sectoral sanctions.

And OFAC acts well beyond U.N. listings, making its own autonomous designations under U.

S. executive orders. When a scenario involves dollars or a U.

S. nexus, OFAC is almost always in play, even if no American is directly a party.

Across the Atlantic, the European Union builds a sanction in two steps: first a Council Decision under the Common Foreign and Security Policy expresses the political will, then a Council Regulation makes it directly binding on persons and entities in E.U. territory.

The E.U. publishes its own Consolidated List.

The United Kingdom used to follow the E.U. regime, but after leaving the Union it now runs its own under the Sanctions and Anti-Money Laundering Act of twenty-eighteen, known as S-A-M-L-A.

The U.K.'s Office of Financial Sanctions Implementation, OFSI, maintains the U.

K. list, issues guidance and licenses, and enforces breaches, including through a strict-liability civil-penalty regime we'll meet later. So remember: E.

U. equals Council Regulation, U.K.

equals O-F-S-I under S-A-M-L-A.

Here's the connection the exam wants you to see. A single target can appear on several lists at once, but the wording, the program, and even the spelling of the name can differ between them. A U.

N. designation flows down into E.U.

, U.K., and other national lists.

The U.S., E.

U., and U.K.

each also add autonomous designations the others may not match, so the lists don't perfectly overlap. For your institution, the practical rule is that you screen against every list relevant to your footprint, your customers, your currencies, and your counterparties, not just one. A firm clearing dollars must heed OFAC even if it isn't American; a firm operating in Europe must heed the E.

U. Regulations.

Two final points. First, the big four aren't the only authorities. Many other countries, Canada, Australia, Switzerland, Japan, and more, run their own regimes, and the Financial Action Task Force, through Recommendations six and seven, pushes every member country to implement targeted financial sanctions for terrorism and proliferation financing.

So your screening universe depends on where you operate and clear. Second, the practical exam habit: when a scenario arrives, first work out the jurisdictional nexus, who the parties are, where the business sits, and what currency clears, because that tells you which regimes bind you. A U.

S. nexus pulls in OFAC; E.U.

territory pulls in the Regulations; a U.K. footprint pulls in O-F-S-I.

In the next lecture, we sort sanctions into their types, comprehensive, list-based, sectoral, and secondary, so you can tell at a glance what a given measure actually prohibits.