OFAC divides its economic restrictions into two operational models: Comprehensive Sanctions and Sectoral Sanctions. A compliance program must configure its screening tools to handle the distinct rules for each model.
Comprehensive Sanctions Programs
Comprehensive sanctions block all trade, financial transactions, and investment with an entire geographic region or country.
  • Target Jurisdictions: Examples include Iran, Cuba, North Korea, Syria, and specific occupied territories.
  • Screening Logic: Systems are configured to block transactions if any participant (sender, receiver, intermediary bank, or vessel owner) is located in, citizen of, or doing business within a comprehensively sanctioned territory.

Sectoral Sanctions Frameworks
Sectoral sanctions restrict specific types of economic transactions with targeted industries or entities within a country, rather than cutting off the entire economy. These are managed via the Sectoral Sanctions Identifications (SSI) List.
[SSI List Match Triggered] ---> Verify Specific Transaction Rules
                                               |
         +-------------------------------------+-------------------------------------+

         |                                                                           |
         v                                                                           v
[Directive 1 Restrictions]                                                  [Directive 3 Restrictions]
- Bans new debt financing over 30 days                                      - Bans new debt financing over 14 days
- Standard commercial trade allowed                                         - Equity transactions allowed

Sectoral screening requires sophisticated systems that evaluate the specific details of a transaction, such as debt maturities and asset types, to determine compliance with individual regulatory directives.
 
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