Sanctions · Types of sanctions · Sectoral sanctions · Secondary sanctions

Types of Sanctions: Comprehensive, Targeted, Sectoral and Secondary

How sanctions differ by scope, instrument and jurisdiction, plus what each type means for screening.

Rosario Andrea Mirante

By

AML Compliance Officer at dilisense

Published 5 min read
Types of Sanctions: Comprehensive, Targeted, Sectoral and Secondary

TL;DR

There are several types of sanctions and no single official taxonomy. The grouping that helps most in compliance runs across three dimensions. By scope, a sanction can be comprehensive, targeted or sectoral. By instrument, it can be economic, diplomatic or military-related. By jurisdiction, it can be primary or secondary. Most real sanctions combine more than one of these. Other classifications exist, both official and academic. This article explains each type, how they differ and what each means when you screen customers and transactions.

Introduction

For what sanctions are, see What are Sanctions?.

How many types of sanctions are there?

You will find different answers depending on where you look. Some sources identify only a handful of types, while others use more detailed classifications. The EU Council, for example, currently lists measures including arms embargoes, travel bans, asset freezes, restrictions on making funds available, economic sanctions and diplomatic sanctions. Academic and policy literature uses other classifications. Sanctions can be grouped in more than one way, so the number depends on how you cut it.

This guide covers the labels you will meet most in compliance, from comprehensive and targeted to sectoral and secondary. To keep them straight, it helps to ask three questions. How wide is the sanction? That is its scope. What tool does it use? That is its instrument. Does it reach beyond the primary target to third parties? That is its jurisdiction. Answer those three and every common type is easy to place.

Comprehensive, targeted and sectoral sanctions

Comprehensive sanctions apply to a whole country or regime. They broadly prohibit trade and financial dealings with the target, subject to licenses and exemptions. North Korea is a commonly cited example of a comprehensive US sanctions regime. US sanctions on Iran are also extensive, although the Iran program combines broad restrictions with targeted, sectoral and secondary measures. Comprehensive sanctions are less common today than targeted measures. Modern UN and EU sanctions regimes generally rely more heavily on targeted and sectoral sanctions, including measures directed at specific individuals, entities or parts of an economy rather than at a country as a whole.

Targeted sanctions, also called smart sanctions, focus on named individuals and entities rather than a whole economy. Asset freezes and travel bans against listed persons are the most common form. The EU, UK and US all maintain freezes and travel bans on individuals and entities listed under their Russia and counter-terrorism programs. The aim is to pressure those responsible while limiting harm to the wider population.

Sectoral sanctions sit between the two. They restrict dealings with a specific part of an economy, such as finance, energy, defense or technology, without blocking the country entirely. They often limit particular activities, such as new debt or equity, rather than freezing a party outright. For example, OFAC's Russia-related directives under Executive Order 13662 restrict dealings in new debt and, depending on the directive, new equity with specified entities in the Russian financial, energy and defense sectors.

Economic, diplomatic and military-related sanctions

Economic sanctions are the largest group. They work through money and trade. Financial measures freeze assets and cut targets off from banking and payment systems. Trade measures restrict what can be bought or sold, from broad embargoes down to specific export controls on sensitive goods. The measures imposed on Russia since 2022 combine both, from frozen central bank reserves and banks cut off from international payment messaging to bans on importing Russian oil. An embargo prohibits trade in specified goods or, in its broadest form, most trade with a target. The US broad trade embargo on Cuba has run for decades.

Diplomatic sanctions work through relationships rather than money. They include expelling diplomats, suspending official visits and withdrawing from cultural or sporting events. Western states expelled hundreds of Russian diplomats in a series of actions in 2022. They signal disapproval without directly restricting trade.

Military-related sanctions restrict defense cooperation. The most common form is an arms embargo. It bans the sale or transfer of weapons to a target and often covers military technology as well. The UN arms embargo on North Korea is one of the longest-standing.

Primary and secondary sanctions

Primary sanctions apply to the persons and entities of the jurisdiction that issues them and to conduct with a connection to it. A US primary sanction, for example, applies to US persons and to conduct with a US nexus, such as a payment cleared through a US financial institution.

Secondary sanctions go further. They can target non-US persons for dealing with a sanctioned party, even where no US person or US nexus is involved. The tool is exclusion rather than prosecution. A firm that trades with a sanctioned party can itself be cut off from the US financial system or added to OFAC's own sanctions lists. US secondary sanctions on Iran have long threatened non-US banks and firms that handle Iranian oil or finance. For how US secondary exposure works in practice, see OFAC Sanctions: An Overview.

Who imposes sanctions

Where a sanction comes from shapes how far it binds. At the top sits the United Nations Security Council, which imposes sanctions through resolutions that all member states are required to implement. That makes UN sanctions multilateral. UN sanctions are given effect through national or regional legal frameworks, according to the requirements of the relevant Security Council resolution.

Most sanctions, though, are regional or national. The European Union adopts measures under its Common Foreign and Security Policy, either to implement UN resolutions or on its own initiative. These apply across all member states (see EU Sanctions). The United States runs one of the broadest national programs through the Office of Foreign Assets Control (OFAC), under laws such as the International Emergency Economic Powers Act (see OFAC Sanctions: An Overview). The United Kingdom implements its financial sanctions through the Office of Financial Sanctions Implementation (OFSI).

Measures a single country adopts alone are called autonomous or unilateral. Measures several states agree together, such as UN or EU sanctions, are multilateral. A party can sit on several of these lists at once, which is why screening has to cover more than one source.

What the types mean for screening

The type of sanction changes what you have to check. Comprehensive programs make the country itself the risk, so screening has to catch exposure to sanctioned jurisdictions, not just listed names. Targeted sanctions put the weight on accurate name screening against current lists. Sectoral measures require you to know the activity and the sector, not only the counterparty. Secondary sanctions mean your risk can come from a partner's dealings, not just your own.

This is why screening has to be broad and current. A name that is clear today can be listed tomorrow. Exposure can also run through ownership rather than the name in front of you. With dilisense you can search OFAC's SDN and consolidated lists, alongside EU, UN, UK and other sources, through a single API. The data updates hourly and every match is traceable to its origin. For how screening works step by step, see What is Sanctions Screening?.

Screen against global sanctions lists

dilisense gives you the EU, UN, UK and US sanctions lists alongside other sources through one API, updated hourly, with every match traceable to its source.

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Frequently asked questions

Sanctions can be classified in different ways. By scope, they can be comprehensive, targeted or sectoral. By instrument, they can be economic, diplomatic or military-related. By jurisdictional reach, they can be primary or secondary. There is no single official taxonomy. Individual sanctions regimes often combine several of these types.

Comprehensive sanctions apply to a whole country or regime and broadly prohibit trade and financial dealings with it. Targeted sanctions, sometimes called smart sanctions, apply to named individuals and entities through measures like asset freezes and travel bans. They aim to pressure those responsible while limiting harm to the wider population.

Secondary sanctions can target non-US persons for dealing with a sanctioned party, even where no US person or US nexus is involved. Rather than prosecuting the third party, they can exclude it from the US market or add it to a sanctions list in its own right.

Sectoral sanctions restrict dealings with a specific part of an economy, such as finance, energy, defense or technology, without blocking the country as a whole. They often limit particular activities, such as new debt or equity, rather than a full asset freeze.

About the author

Rosario Andrea Mirante

AML Compliance Officer at dilisense

Rosario Andrea Mirante is a legal expert at dilisense, covering sanctions, AML and KYC with a focus on key legal and regulatory developments.

  • Sanctions screening
  • Anti-money laundering (AML)
  • Know your customer (KYC)
  • Politically exposed persons (PEP)
  • Regulatory compliance

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