GLOBAL RESTRICTIONS: THE VAGARIES OF SANCTIONS COMPLIANCE

In a world of shifting geopolitical tensions, the international sanctions landscape has become increasingly complex and dynamic – an arena in which governments and international bodies frequently update sanctions lists in response to hostile and serious global events.

Acting as the foundational baseline for global sanctions compliance are 15 United Nations (UN) sanctions regimes, each administered by a sanctions committee chaired by a non-permanent member of the UN Security Council. Ten monitoring groups, teams and panels support the work of 11 of the 15 sanctions committees.

Because all 193 UN member states are legally bound to enforce these sanctions, they represent the broadest global consensus on restricting hostile actors, weapons proliferation and human rights abusers.

UN sanctions require agreement from all five permanent Security Council members: the US, UK, France, China and Russia. Often representing the lowest common denominator, many UN sanctions are preceded by, or quickly followed by, stricter unilateral measures introduced by Western powers.

“The last decade has seen a staggering evolution in the complexity of sanctions designations,” says Marco Dias Roque, a director at LSEG Risk Intelligence. “Going all the way from pure list designations to sanctions that extend to non-listed entities through ownership or control relationships.

“More recently, we have seen restrictions on securities, debt, investment and financing activities,” he continues. “When coupled with different, and often conflicting, regulatory expectations from different jurisdictions in the trade compliance space, organisations have their work cut out for them when it comes to compliance.”

Oct-Dec 2026 Issue

Fraser Tennant