CGSS key terms

Coercive measures imposed by governments or multinational bodies to restrict economic activity with targeted countries, entities, or individuals in order to change behavior or limit capabilities.

Broad restrictions that prohibit most trade, financial transactions, and investment with an entire country or territory, often with limited exceptions for humanitarian goods.

Restrictions aimed at specific individuals, entities, sectors, or activities rather than a whole country, designed to reduce humanitarian harm while pressuring decision-makers.

Measures that bind persons subject to a sanctioning authority's jurisdiction, such as its citizens, residents, and companies, regardless of where the transaction occurs.

Measures that threaten penalties against non-US persons for dealings with a sanctioned target that lack a direct US jurisdictional link, aiming to deter third-country activity.

The application of a country's laws beyond its borders, such as requiring foreign firms to comply with sanctions when handling US-origin goods, US dollars, or US persons.

A requirement to block property and interests in property of designated persons, prohibiting transfers or dealings without authorization and often requiring reporting to authorities.

An authorization from a sanctions authority permitting an otherwise prohibited transaction; general licenses apply automatically to a category, while specific licenses cover named parties.

A published authorization that permits a defined category of otherwise prohibited transactions without a case-by-case application, often subject to conditions and reporting.

Restrictions on specific sectors or types of transactions with named entities, such as limiting new debt or equity, rather than fully blocking all dealings.

A public US Treasury list of individuals and entities owned or controlled by, or acting for, sanctioned targets; US persons generally must block their property and avoid dealings.

The US Treasury office that administers and enforces most US economic sanctions, maintains the SDN List, issues licenses, and imposes civil penalties.

The UK Treasury body responsible for implementing financial sanctions, maintaining the consolidated list, issuing licenses, and enforcing compliance.

Restrictive measures adopted by the European Union, often implementing UN resolutions or autonomous EU decisions, applied through regulations binding on member states.

A binding decision by the UN Security Council that can impose sanctions on states, entities, or individuals, which member states must implement under international law.

The US rule that entities owned 50 percent or more, directly or indirectly, by one or more blocked persons are themselves treated as blocked even if not listed.

A US Commerce Department list of foreign parties requiring a license for exports of specified items, often due to national security or proliferation concerns; it is not itself a sanctions list.

A documented set of policies, controls, and governance arrangements designed to prevent, detect, and respond to sanctions violations across an organization's activities.

A structured process to identify, evaluate, and prioritize sanctions risks based on customers, products, geography, transactions, and delivery channels, updated periodically.

The procedures and systems, such as screening, approval workflows, and escalation rules, that operationalize an organization's sanctions policies and prevent prohibited transactions.

Visible support from executive leadership and the board, including adequate resources, clear accountability, and a culture that prioritizes sanctions compliance.

Periodic review of a sanctions compliance program by internal audit or an external party to assess effectiveness and identify gaps, with findings reported to senior management.

Corrective actions taken to fix identified compliance weaknesses, including policy changes, system fixes, lookbacks, and staff training, with tracking to completion.

Comparing customers, counterparties, transactions, or shipments against sanctions lists and other watchlists to identify potential matches before or during a transaction.

A screening technique that identifies near matches by allowing minor differences in spelling, transliteration, or word order, increasing detection but also false positives.

A screening alert that resembles a listed name or entity but, after review, is not the sanctioned party; it must be documented and cleared.

The process of reviewing and prioritizing screening or monitoring alerts to decide whether they require escalation, clearance, or further investigation.

Ongoing review of transaction patterns and data to detect activity that may violate sanctions, such as dealings with blocked persons or prohibited sectors.

A structured inquiry to determine whether an alert or reported conduct involves a sanctions violation, including fact-gathering, documentation, and a reasoned conclusion.

Deliberate conduct to circumvent sanctions restrictions, such as hiding ownership, misrepresenting goods, or routing transactions through intermediaries.

Breaking transactions into smaller amounts or splitting them across parties or accounts to avoid triggering reporting thresholds or scrutiny.

An entity with no substantive operations or assets, often used to conceal the true owner or counterparty in a transaction.

Routing goods through an intermediate country to disguise their origin or destination, often to evade sanctions or export controls.

Items, software, or technology with both civilian and military or proliferation applications, often subject to export controls and heightened sanctions scrutiny.

A monetary fine imposed by a regulator for a sanctions violation, often calculated under statutory guidelines and potentially settled without admission of liability.

A formal regulatory response to suspected sanctions violations, which may include warnings, fines, settlements, license denials, or criminal referral.

Reporting one's own apparent sanctions violation to the authorities before they discover it, typically treated as a mitigating factor that can reduce penalties.

Circumstances that reduce culpability or penalty severity, such as self-disclosure, remedial steps, cooperation, and a strong compliance program.

Circumstances that increase penalty severity, such as deliberate concealment, senior management involvement, repeat violations, or harm to sanctions objectives.