OFAC, EU, UK and UN sanctions lists compared

A sanctions lists comparison distinguishes four institutional regimes: OFAC lists in the United States, the UK Sanctions List, EU restrictive measures, and UN Security Council lists. Each has a separate legal basis, maintainer, scope, and delisting route.

The common label of sanctions list can obscure different legal effects. Some lists are administered by a national authority, some by a regional legal order, and some originate at the United Nations Security Council. A bank credit desk sees them as related reference points, but the institutional source of a name determines the relevant law, jurisdictional reach, and route for reconsideration.

This article treats the lists as public law instruments, not as operational data sets. The focus is on institutional control: who maintains each list, what legal basis supports it, what listing scope each authority describes, and how delisting works where a formal route exists.

Sanctions lists comparison by maintainer and basis

OFAC is part of the United States Treasury and administers United States sanctions. It maintains the Specially Designated Nationals and Blocked Persons List, commonly called the SDN List, and other non-SDN sanctions lists. OFAC states that the assets of SDNs are blocked and that United States persons are generally prohibited from dealing with them. Its legal bases include the Trading With the Enemy Act and the International Emergency Economic Powers Act.

The UK position is split between two institutions. The Foreign, Commonwealth and Development Office maintains the UK Sanctions List under the Sanctions and Anti-Money Laundering Act 2018, as described in the government comparative overview current as of 28 January 2026. The Office of Financial Sanctions Implementation implements UK financial sanctions against those listed. The same overview describes OFAC as the United States sanctions administrator and OFSI as the United Kingdom financial sanctions implementer.

The European Union adopts sanctions through its own treaty framework. Article 29 of the Treaty on European Union provides for Council decisions under the Common Foreign and Security Policy, adopted by unanimity. Economic and financial measures are then given effect through Article 215 of the Treaty on the Functioning of the European Union, using regulations. The EU implements United Nations Security Council sanctions and also adopts autonomous sanctions.

The United Nations Security Council operates through Security Council sanctions regimes. For the ISIL and Al-Qaida list, the United Nations Ombudsperson mechanism was established by Security Council Resolution 1904 (2009). Security Council Resolution 2734 (2024) extended the Ombudsperson's mandate until June 2027. This list has its own delisting channel through the Ombudsperson, who reports a recommendation to the relevant Committee.

Listing scope and legal effect

OFAC's SDN List has a direct blocking consequence under United States sanctions law. OFAC describes SDNs' assets as blocked, with United States persons generally prohibited from dealing with them. The existence of other non-SDN lists matters because not every OFAC list carries the same description as the SDN List. A comparison based only on a name match loses that institutional distinction.

The UK Sanctions List is the consolidated list maintained by FCDO for United Kingdom sanctions designations. OFSI implements financial sanctions against those listed. The government comparison distinguishes the OFAC SDN List from the UK Sanctions List and describes the jurisdictional frame in terms of United States persons and United Kingdom persons. That distinction matters because the legal source is national law in each case.

EU restrictive measures sit within the EU legal order. The Council adopts Common Foreign and Security Policy decisions under Article 29 TEU, while measures such as economic and financial restrictions are implemented through Article 215 TFEU regulations. EU sanctions therefore combine a political decision with a regulation where binding economic and financial measures are required.

UN Security Council sanctions are not the same as autonomous national or EU designations. The EU implements UN Security Council sanctions, and national systems may also give effect to UN obligations through their own domestic arrangements. The United Nations source remains relevant because the delisting route for the ISIL and Al-Qaida list is described through the Ombudsperson rather than a national treasury or foreign ministry process.

Delisting and reconsideration routes

OFAC describes an administrative reconsideration process under 31 CFR section 501.807. A person seeking removal may use the OFAC Reconsideration Portal. OFAC states that petitions may be granted or denied. If a petition is denied, a further application may be made with new evidence. This is a national administrative route inside the United States sanctions system.

The UK route is statutory. Under section 23 of the Sanctions and Anti-Money Laundering Act 2018, a designated person may request the Minister to vary or revoke the designation at any time while it has effect. A further request in respect of the same designation requires a significant matter which has not previously been considered by the Minister. The institutional distinction is central: United Kingdom designations are reconsidered under United Kingdom sanctions legislation, not under the United States Treasury's administrative process.

For EU restrictive measures, reconsideration runs through the Council and the European courts. A listed person has the right to make representations to the Council and request the Council to de-list them, and the right to bring a legal challenge and contest the listing in front of the European courts. The measures themselves are adopted through Article 29 TEU and Article 215 TFEU, and the EU also implements United Nations Security Council sanctions, so some EU measures correspond to UN obligations while others are autonomous.

For the UN ISIL and Al-Qaida list, a delisting request is made to the Ombudsperson. The Ombudsperson reports a recommendation to the Committee. That structure differs from OFAC administrative reconsideration and from EU or UK institutional channels. It is a Security Council mechanism with a defined mandate and Committee recommendation process.

Relevance for bank credit desks

For bank credit desks, the four regimes relate as separate legal sources that may all be relevant to a counterparty, sponsor, borrower, guarantor, or transaction party. The core distinction is institutional rather than technical. OFAC, OFSI, the EU, and the United Nations do not maintain one shared list with one legal consequence. They maintain or implement sanctions through separate authorities.

This matters in credit analysis because a sanctions designation may affect capacity to contract, receive funds, hold assets, or participate in a financing. The legal consequence depends on the list and the applicable jurisdiction. OFAC's SDN List carries the described blocking consequence for United States persons. The UK Sanctions List is maintained by FCDO and implemented for financial sanctions by OFSI. EU restrictive measures arise through the EU treaty process. UN listings sit within Security Council regimes and may be implemented by other legal systems.

The relationship among the regimes is also hierarchical in some cases and autonomous in others. The EU implements United Nations Security Council sanctions, but it also adopts autonomous sanctions. The United States and United Kingdom maintain their own sanctions authorities. A designation in one regime is therefore not automatically the same legal act as a designation in another, even where names overlap across public lists.

For institutional credit work, this comparison supports clear categorisation of legal source and authority. It does not replace legal analysis of a particular designation or transaction. It defines the main public regimes, their maintainers, their legal basis, and the delisting route where a formal one exists.