EU sanctioned persons: who you cannot pay, supply or trade with
Not checking is no defence - and a breach can mean up to five years in prison
An EU sanctioned person is any individual or entity that the Council of the European Union has placed on its sanctions list - in legal terms, 'listed' - often triggering a freeze on their assets and a ban on making funds or economic resources available to them, directly or indirectly. The ban follows the person, not the goods: even an entirely unrestricted product cannot be supplied to a designated party.
Who is a sanctioned person?
A sanctioned person is any individual or entity - a company, group or other body - that the Council of the EU has placed on a restricted list. Designation does not always carry the same measures, but it typically brings:
- an asset freeze on the person's funds and economic resources;
- a ban on making funds or economic resources available to them, directly or indirectly;
- for individuals, a travel ban.
'Person' here covers organisations, not just individuals. Objects can be listed too - notably vessels and aircraft - but under controls specific to them rather than as sanctioned persons.
Who is bound by EU sanctions?
EU nationals and EU-incorporated companies are bound wherever in the world they operate. EU sanctions also bind anyone acting within the EU - so a company based outside the EU is caught whenever its deal has an EU link: it runs through an EU bank, branch or intermediary, involves EU-origin goods, or is carried out partly within the EU. A non-EU company can also be listed directly, including for circumvention, in which case it is caught in its own right. A company that is not on any list is still caught if a listed person owns 50% or more of it or controls it; see the 50% rule below.
Who designates EU sanctioned persons?
The Council of the EU designates them. It adopts legal acts - regulations and decisions - under the EU's Common Foreign and Security Policy (CFSP), usually on a proposal from the High Representative for Foreign Affairs and Security Policy and/or the European Commission. These acts name the individuals and entities subject to sanctions. Once adopted, the designations are published in the Official Journal of the EU and compiled into the EU consolidated list, which the Commission maintains and makes publicly searchable.
What is prohibited when dealing with a sanctioned person?
EU operators must freeze all funds and economic resources belonging to, owned, held or controlled by a designated person, and must not make funds or economic resources available to them, directly or indirectly. 'Indirectly' is what catches the party behind the party: supplying or paying a company that a listed person owns or controls is treated as making funds available to the listed person - even where that company appears on no list. This is the 50% ownership and control rule, and it is where most screening fails.
An asset freeze is one type of listing. A name or object can also be caught by an export-control entity listing, a vessel listing or a transaction ban - each with a different prohibition and often a different date - explained in 'EU sanctions: where listed and what consequences' (CCRM 40, 2026).
Where is the EU sanctions list published?
The authoritative source is the Official Journal of the EU - only what is published there is legally binding. For practical screening, the EU Sanctions Tracker lets you search the persons, groups and entities currently under EU financial sanctions and travel bans, and see the detail behind each listing. To check which sanctions regimes apply to a country or theme, including UN sanctions, use the EU Sanctions Map - but note it is regime-level: it shows which rules exist, not whether your counterparty is caught by them. SMEs can also get free guidance from the EU Sanctions Helpdesk.
Some member states also publish national lists of companies they treat as owned or controlled by listed persons. Those lists implement the EU freeze; they do not add to it, and the Court of Justice has held that a company on such a list must be given reasons and a way to challenge it.
What are the penalties for dealing with a sanctioned person?
Not having checked is no defence: liability follows where you knew or had reasonable cause to suspect that a listed person was behind the counterparty. Directive (EU) 2024/1226 required member states to criminalise intentional sanctions violations by 20 May 2025, with a maximum of at least five years' imprisonment for individuals where the value is EUR 100,000 or more, and fines for companies of at least 5% of worldwide turnover or EUR 40 million. Trading in military or dual-use goods contrary to sanctions must be a crime even where the breach was only seriously negligent. Implementation is uneven: some member states transposed on time, and the Commission has opened infringement proceedings against those that missed the deadline.
Use case
An export of ordinary handbags can be prohibited - not because of the commodity, but because the recipient is a designated entity. The Sanctions AI assistant screens persons and entities against EU designations, including known aliases and related entities - try it free.
