Lesson 02 of 25
What Sanctions Are and Why Governments Use Them
5 min read · CGSS
Define economic and financial sanctions in plain English and separate them from export controls and money laundering. Learn the coerce-constrain-signal logic behind sanctions and the legal authorities (IEEPA, UN Charter Article 41) the exam expects you to name.
What 'sanctions' means
- Restrictive measures imposed by governments/bodies
- Financial, trade, travel, sectoral, or arms measures
- A foreign-policy and security tool — not a tax or a fine
- Goal: change behavior without (usually) using force
Let's define the thing precisely, because the exam rewards precision. Sanctions, sometimes called restrictive measures, are tools a government or international body uses to change the behavior of a target by restricting its access to money, goods, markets, or travel. They can be financial, freezing assets and blocking transactions; trade-based, banning exports or imports; sectoral, hitting a specific industry like energy or defense; or they can restrict travel and arms.
The key idea is that a sanction is an instrument of foreign policy and national security, a way to apply pressure without sending in the military. The U.N.
Charter captures this in Article forty-one, which lets the Security Council take measures not involving armed force. Hold that purpose in mind, because it explains why sanctions look the way they do.
Why governments impose them
- Counter-terrorism and proliferation
- Respond to aggression, human-rights abuses, corruption
- Coerce, constrain, or signal — three classic aims
- Targeted to pressure regimes, not (ideally) civilians
Why do governments reach for sanctions? Broadly, to counter threats like terrorism and the spread of weapons; to respond to aggression, human-rights abuses, or grand corruption; and to signal disapproval to allies and adversaries alike. Scholars describe three classic aims: to coerce a target into changing course, to constrain its ability to act by cutting off resources, and to signal a norm has been broken.
Modern sanctions are increasingly targeted, aimed at specific leaders, entities, and sectors rather than whole populations, precisely so the pressure lands on decision-makers rather than ordinary civilians. When the exam asks why a measure exists, this purpose lens, coerce, constrain, signal, is the reasoning it wants.
Sanctions vs. export controls vs. AML
- Sanctions — prohibit dealing with targets (who/what)
- Export controls — restrict moving controlled goods/tech
- AML — risk-based detection of criminal proceeds
- They overlap, but the exam wants the distinctions
Three neighboring areas get confused, so let's separate them. Sanctions prohibit dealing with a target, focused on who or what is off-limits. Export controls restrict the movement of specific controlled goods, software, and technology, often dual-use items that have both civilian and military uses, focused on what's being shipped and to whom.
Anti-money laundering is risk-based detection of criminal proceeds, focused on suspicious behavior. These overlap constantly in real life, a dual-use shipment to a sanctioned end-user is all three at once, but the exam wants you to know which framework governs. When the controlling fact is a designated party, that's sanctions.
When it's a controlled commodity, that's export control. When it's hidden criminal money, that's A-M-L.
The legal authority behind a sanction
- US: IEEPA (50 USC 1701) and older TWEA
- President declares a national emergency, then acts
- OFAC writes and enforces the regulations
- EU: Council Decisions + Regulations under CFSP
Where does the legal power to impose a sanction come from? In the United States, the main authority is the International Emergency Economic Powers Act, IEEPA, found at fifty U.S.
Code section seventeen-oh-one and following. Under IEEPA, the President declares a national emergency in response to an unusual and extraordinary threat, then issues an executive order, and OFAC writes and enforces the detailed regulations in title thirty-one of the Code of Federal Regulations. An older statute, the Trading with the Enemy Act, or T-W-E-A, still underpins a few programs like Cuba.
In the European Union, sanctions begin with a Council Decision under the Common Foreign and Security Policy and are made legally binding through a Council Regulation that applies directly across member states. The exam likes to ask which authority sits behind a U.S.
or E.U. measure, so anchor I-E-E-P-A for the U.
S. and Council Regulation for the E.U.
Programs, designations, and prohibitions
- Program — a sanctions regime (e.g., country or theme)
- Designation — adding a person/entity to a list
- Prohibition — what you may not do as a result
- Same vocabulary across regimes — learn it once
Three words recur across every regime, so learn them once. A program is a sanctions regime, often built around a country or a theme like terrorism or cyber. A designation is the act of adding a specific person or entity to a list under that program.
And a prohibition is what the law forbids you to do as a result, typically dealing with, providing services to, or making funds available to the target. So a program creates the rulebook, a designation names a target, and the prohibition tells you to stop. Keep that chain in mind, because every exam scenario is really asking which program applies, who's designated, and what's prohibited.
Why the purpose lens helps you answer
- Sanctions follow foreign policy, so they change fast
- Same target can be hit by several bodies at once
- The 'why' explains the breadth of a prohibition
- Next: the four bodies that run the programs
Before we move on, hold onto why all this matters for the exam. Because sanctions are a foreign-policy tool, they change quickly as politics shift, which is why list currency and constant vigilance are themes you'll see throughout the course. Because the same threat worries many governments, the same target is often designated by several bodies at once, under programs with different names and slightly different rules.
And because the goal is to deny a target money, goods, and access, prohibitions are written broadly, reaching indirect dealings and not just the obvious direct ones. When a scenario feels expansive, that breadth is deliberate, it reflects the purpose. In the next lecture, we meet the four major bodies that run these programs, the United Nations, OFAC, the European Union, and the U.
K.'s O-F-S-I, and we'll see how a single U.N.
listing can ripple into every national regime at once.
Sources
- UN Charter Article 41 (UN Security Council measures not involving armed force)
- IEEPA — International Emergency Economic Powers Act, 50 U.S.C. 1701 et seq.
- Trading with the Enemy Act (TWEA)
- OFAC 31 CFR Chapter V
- EU sanctions under the Common Foreign and Security Policy (CFSP)
Test your knowledge
A few CGSS questions on this material — pick an answer to see the explanation.
Q1. According to OFAC's Framework for Compliance Commitments, which is one of the five essential components of a risk-based sanctions compliance program?
Q2. In OFAC's enforcement analysis, what is the single most frequently cited root cause of sanctions compliance program breakdowns?
Q3. A global bank routes all USD payments through a U.S. correspondent but applies sanctions screening only to customers domiciled in the United States. Which Framework component is most directly deficient?
Q4. How do restrictions on parties on the Sectoral Sanctions Identifications (SSI) List differ from those on the SDN List?