Individuals and entities targeted by a sanctions regime are often referred to as “listed” or “designated.” It is worth noting that if more than 50% of an entity is owned (directly or indirectly) by a designated person, financial sanctions will apply to that entity as well.

Where the sanction at issue is an asset freeze, as is most often the case, transactions with listed individuals and entities are generally prohibited. However, the nature of the restriction is governed by the relevant statutory instrument, which even in the case of asset freezes, is not identical across statutes. Accordingly, the restrictions and conditions set out in the relevant statutory instrument must be considered whenever a potential connection to a sanctions target is identified.

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