DPS Sanctions Philosophy: Understanding Sanction Target Types
The purpose of this section is to elaborate on the criteria that the ONESOURCE Global Trade Content team uses to determine whether to add a sanction or embargo to Denied Party Screening (DPS).
Since sanctions and embargoes vary by regulation list, the number of hits received for sanctions and embargoes depends on which regulation list(s) the you opt to screen (for example, OFAC Sanctions, UN Sanctions).
Since sanctions and embargoes are presented the same way within DPS, the word “sanction” refers to both sanctions and embargoes for the purposes of the DPS Sanctions Philosophy section.
Restrictions vs. Targets
The restrictions imposed by sanctions vary widely. Examples include, but are not limited to:
- Arms Embargoes
- Asset Freezes
- Import/Export Restrictions
- Financial Sanctions
- Technical Assistance Restrictions
- Travel Bans
- Vessel Restrictions
- Cultural Property Restrictions
Sanction targets also vary widely, ranging from specific individuals to entire countries. Since the purpose of DPS is to screen for prohibited or restricted parties, ONESOURCE analyzes the sanction target (and not the specific restriction) to determine how that sanction is treated within DPS.
Sanction Target Types
Country-Wide Sanctions
A country-wide sanction applies to the entire country. The nature of the restriction(s) may vary, but the unifying factor is that the regulations apply country-wide. Examples include:
- An arms embargo against North Korea
- Financial sanctions against Myanmar
- Export restrictions for Liberia
Parties where the address country is subject to a country-wide sanction will show a hit in DPS.
ANY_ADDRESS
and ANY_CITY
indicate the sanction applies to all addresses and cities within the sanctioned country.
Country-State-Wide Sanctions
To assess the risk of doing business with entities located in a sanctioned region, you can screen records to identify if there are sanctioned regions within a specific sub-country. You can do this by providing details such as the country, state/province, or territory.
Example 1:
selecting a specific country and state/province, you will receive hits that include:- The selected country and state/province.
- The selected country without a specific state/province.
- Other entries that match your search criteria.
Example 2:
selecting only a specific country, you will receive hits that include:- The selected country with all possible states/provinces, sorted alphabetically.
- The selected country without specifying any state/province.
Regional Sanctions
A regional sanction will apply to a specific region either within one country (Crimea region of Ukraine, for example) or multiple countries (for example, Western Balkans). Like country-wide sanctions, specific restrictions may vary, but the unifying factor is the geographical range affected by the sanction. Within DPS, regional and country-wide sanctions are presented in a similar manner.
Parties where the address country includes a sanctioned reason will show hits with
ANY_ADDRESS
and ANY_CITY
. 
Since regional sanctions typically target a very general geographical location, hits for regional sanctions may still occur even if the screened address is outside the sanctioned region of a country. Therefore, even a specific street address, city, and state may not be enough to determine if a location is within the sanctioned region.
However, regional sanctions will include a note on the
Exceptions
tab of the Denied Party Entity Detail
window, indicating the specific area to which the sanction applies.
Country-Related Sanctions
A country-related sanction will apply to specific people or organizations connected to a country. For example, OFAC publishes
Yemen-Related Sanctions
, which applies to people and organizations threatening the peace and stability of Yemen (not against the country of Yemen as a whole).People and organizations associated with a country-related sanction may not necessarily be located within the country. Continuing with this example, someone could still threaten the peace and stability of Yemen from another country, especially if that person is a fugitive.
Targets of country-related sanctions are generally published on a separate list. For example, OFAC maintains numerous country-related sanctions for which the targeted people or organizations are published on the Specially Designated Nationals (SDN) list. When these lists are available, the Global Trade Content team incorporates them into DPS. This way, clients can still find hits on the targeted people or organizations associated with a country-related sanction without receiving hits for the country itself.
Other Sanctions Regimes
Some sanctions are related to specific individuals or organizations independent of geography. These sanctions regimes are usually grouped by the type of illicit activity (for example, Narcotics Trafficking, Terrorism). The targets’ names are published in a separate list provided by the government or organization imposing the sanction. When these lists are available, the Global Trade Content team incorporates them into DPS.
Within DPS, these sanctions programs are presented in a similar manner as country-related sanctions. Clients can still find hits on the targeted people or organizations without receiving a country-level hit.
Related Content
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DPS Settings: Advanced Sanction/Embargo Management
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