What does a listing actually prohibit?
Blocking property, restricting accounts, and prohibiting investments have different effects.
Sanctions can require property to be frozen, or prohibit a particular kind of financing or investment. For a transaction, the key questions are what the rule prohibits, who must comply, and whether an authorization applies.[10]
Blocking: the owner keeps title, but cannot freely use the property
Blocking prevents transfers or other dealings in the property. Property that must be blocked is covered when it is in the United States or in a U.S. person’s possession or control. Blocking is not confiscation, and the property cannot simply be returned without authorization.[01]
Property is broader than a bank balance: it can include shares, debt, goods, real estate, and other interests. Avoiding a payment does not by itself resolve every restriction.[01]
Where do common restrictions apply?
These are common restrictions, not every possible case. The CAPTA row uses the Russia-related directive as an example; other programs have their own rules. More than one restriction can apply to a target.[19][20][23]
Is rejecting a payment the same as freezing it?
Block
There is a blockable interest in the property: hold it under the applicable rules rather than transferring or returning it.
Reject / do not proceed
The activity is prohibited but there is no blockable interest: it may need to be rejected rather than blocked.
The person or institution blocking or rejecting a transaction may also need to report it and keep records. Required reports are generally due within 10 business days; the rules in force determine the details.[12][21]
Does this matter outside the United States?
U.S. citizens and permanent residents generally must comply wherever they are. The rules also cover people and entities in the United States, U.S.-incorporated entities, and their foreign branches. Certain programs also cover foreign subsidiaries owned or controlled by U.S. persons.[09]
Non-U.S. persons can also be subject to certain prohibitions. For a transaction abroad, examine the involvement of U.S. persons or banks, property in the United States, and the program’s rules for the conduct in question. Location, nationality, or currency alone does not settle the question.[09][10]