CGSC key terms

Restrictive measures imposed by governments or international bodies to influence behaviour, typically by limiting dealings with specific people, entities, sectors or countries.

The documented policies, procedures, controls and governance an organisation uses to identify, assess, mitigate and monitor sanctions risk.

A structured evaluation of how exposed an organisation is to sanctions risk, considering customers, products, jurisdictions, channels and transactions, and how severe and likely each exposure is.

Allocating compliance resources and controls in proportion to assessed risk, so higher-risk relationships receive more scrutiny than lower-risk ones.

An individual or entity named on a sanctions list, meaning dealings with them are restricted or prohibited and their assets may be frozen.

An official register published by an authority that names individuals and entities subject to restrictions, such as consolidated, OFAC, EU or UN lists.

A single combined reference compiling multiple sanctions lists so that screening can be run against several regimes at once.

A prohibition on dealing with, moving or using funds and economic resources owned or controlled by a designated person, without prior authorisation.

Assets of any kind, including funds, property and goods, that can be used to obtain funds or services; freezing them prevents their use or transfer.

Financial assets and benefits of every kind, such as cash, deposits, securities, credit balances and payment instruments, that sanctions restrictions commonly target.

Holding a direct or indirect legal interest in an entity, often measured by percentage shareholding, which can cause a person's designation to extend to that entity.

The ability to direct an entity's actions or policies, whether through majority ownership, board control, contractual rights or other means, even without a formal ownership stake.

The principle that an entity owned 50 percent or more, directly or indirectly, by one or more designated persons is itself treated as designated.

Restrictions targeting specific industries or activities, such as energy or finance, rather than naming particular individuals or entities.

Broad restrictions applying to an entire country or territory, covering most dealings and trade rather than only named persons or sectors.

A government order restricting trade with a particular country or in particular goods, often banning exports, imports or both.

Rules governing the sale, transfer or re-export of sensitive goods, software and technology, often applied alongside sanctions to prevent proliferation or military use.

Items, software or technology that have legitimate civilian uses but can also serve military or weapons-related purposes, making them subject to licensing controls.

Measures that threaten penalties against non-designated third parties, including foreign firms, for engaging in specified dealings with a sanctioned target.

Restrictions that apply directly to persons within the imposing authority's jurisdiction, prohibiting them from dealings with designated targets.

The application of one country's sanctions laws to conduct or persons outside its borders, often through links such as US dollar clearing or US-origin goods.

The legal authority of a state or regulator over persons, entities or transactions, which determines whose sanctions rules apply to a given activity.

Deliberately structuring transactions, ownership or trade routes to evade sanctions restrictions, for example by using intermediaries or obfuscating beneficial ownership.

The automated or manual process of comparing customers, counterparties or transactions against sanctions and other lists to identify potential matches.

The technique used in screening to compare names against list entries, allowing for spelling variations, transliteration differences and partial matches.

A screening alert that resembles a listed name or entity but, after review, is confirmed not to be a true match.

A failure to flag a customer or transaction that should have matched a sanctions list, representing a serious control gap.

The process of reviewing and clearing or escalating screening and monitoring alerts, using defined criteria and documented rationale.

The baseline process of identifying customers, verifying their identity and understanding their business and expected activity before and during a relationship.

Additional, more intensive checks applied to higher-risk customers or relationships, such as source of funds and wealth verification or senior management approval.

The natural person who ultimately owns or controls a customer or the entity behind a transaction, identified through ownership and control analysis.

The framework of identification, verification and ongoing monitoring measures used to establish who a customer is and whether their activity is expected.

The origin of the money used in a specific transaction or relationship, examined to confirm it is legitimate and not linked to sanctioned activity.

The origin of a customer's overall assets and income, examined to confirm legitimacy and to identify any connection to sanctioned persons or sectors.

Continuous or periodic review of customer activity and list changes to detect unusual behaviour or newly designated parties after onboarding.

Automated or manual review of transaction patterns against expected activity and sanctions indicators to detect prohibited dealings or evasion.

A warning indicator suggesting possible sanctions or evasion risk, such as unusual routing, opaque ownership or reluctance to provide information.

The documented process of referring a potential sanctions issue to compliance, legal or senior management for decision and possible reporting.

A transaction that is stopped and the related property held because it involves a designated person or otherwise prohibited dealing.

The duty to notify regulators or authorities of blocked transactions, matches to designated persons or suspected sanctions breaches within required timeframes.

A written statement of an organisation's sanctions commitments, responsibilities and prohibited conduct, approved by senior management.

The oversight structure for sanctions compliance, including board and senior management accountability, clear roles and adequate resourcing.

Regular education for staff on sanctions rules, red flags and their responsibilities, tailored to the risks of their role.

Periodic review of a sanctions programme by a function independent of compliance operations, to verify controls work as designed and identify gaps.

A complete, retrievable record of decisions, alerts, screenings and approvals that demonstrates how sanctions controls operated.

The authority that supervises compliance with sanctions rules and may investigate breaches and impose penalties or enforcement action.