In law, the sanctioned meaning most people are looking for is the punishment sense: to be sanctioned is to have a government, court, or international body impose a formal penalty or restriction on you for breaking a rule. The word can also mean “officially approved,” but in legal usage it almost always points the other way. Sanctions show up in two very different places. Internationally, they are economic and diplomatic measures (frozen bank accounts, trade bans, travel prohibitions) aimed at countries, companies, or individuals. In American courtrooms, sanctions are penalties a judge imposes on a lawyer or party who abuses the litigation process. The consequences are serious in both settings, with civil penalties reaching into the hundreds of thousands of dollars per violation and criminal exposure of up to 20 years in prison for willful breaches of U.S. sanctions law.
The Two Legal Senses of “Sanctioned”
English gives the word an awkward double life. A legislature can sanction a law by approving it. A judge can sanction a lawyer by punishing one. Legal writing almost always means the second. A sanction is a penalty tied to a specific rule, whether that rule sits in a federal statute, a procedural code, or a United Nations resolution.
Across every setting the structure is the same. Someone broke a rule, and the sanctioning authority is making it costly enough to compel a change in behavior. What differs is who imposes the sanction, what rule was broken, and how severe the penalty can run.
Who Can Impose Sanctions
At the international level, the UN Security Council acts under Article 41 of the UN Charter, which lets it adopt measures short of armed force (interrupting economic relations, cutting communications, severing diplomatic ties) to maintain or restore international peace.1United Nations. Chapter VII Action with Respect to Threats to the Peace Member states are expected to implement its resolutions.2United Nations. Security Council Sanctions
Inside the United States, the Office of Foreign Assets Control (OFAC), housed in the Treasury Department, runs the country’s economic sanctions programs. Its authority flows from the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA), both triggered by a presidential declaration of national emergency.3Office of Foreign Assets Control. FAQ 61 OFAC maintains the sanctions lists, issues licenses that authorize otherwise prohibited transactions, and brings enforcement actions.
Federal judges hold their own, narrower sanctioning power. Rule 11 of the Federal Rules of Civil Procedure says that any attorney or self-represented party who files a document is certifying it is not being submitted for an improper purpose and that its legal arguments are not frivolous. If a court finds a violation, it can order monetary fines, require payment of the other side’s attorney fees, or impose nonmonetary consequences such as striking a pleading.4Legal Information Institute. Federal Rules of Civil Procedure Rule 11 Administrative agencies impose their own penalties for breaches of industry-specific rules.
What a Sanction Actually Looks Like
International sanctions come in several forms, and a single program usually combines more than one.
- Asset freezes. The target loses access to bank accounts, real estate, and other property within the sanctioning country’s jurisdiction. The property is not seized permanently; it is held in place and cannot be moved or used.
- Trade embargoes. Most or all commercial dealings with the targeted country or entity are prohibited, including shipments of goods, technology, and dual-use items that serve both civilian and military purposes.
- Financial restrictions. Banks and payment processors are barred from handling transactions involving the target, effectively cutting them out of the global financial system.
- Travel bans. Designated individuals cannot enter the sanctioning country.
- Diplomatic measures. Embassies may be closed and official communications severed.
Court-imposed sanctions look different in kind. A judge might strike a pleading so a party cannot raise certain claims or defenses, order payment of opposing counsel’s fees, or hold a party in contempt for ongoing refusal to obey a court order.4Legal Information Institute. Federal Rules of Civil Procedure Rule 11
Consequences of Violating U.S. Sanctions
This is where people are often caught off guard. Breaking a U.S. sanctions rule is not a minor regulatory lapse. Civil and criminal penalties stack up quickly, and they apply to individuals and companies alike.
Civil Penalties
Under IEEPA, the statutory base civil penalty is the greater of $250,000 or twice the value of the underlying transaction.5Office of the Law Revision Counsel. 50 USC 1705 Penalties That figure is adjusted every year for inflation. As of January 2025, the inflation-adjusted maximum civil penalty under IEEPA is $377,700 per violation, and penalties under TWEA reach $111,308 per violation.6Federal Register. Inflation Adjustment of Civil Monetary Penalties Each individual transaction can count as a separate violation, so a pattern of prohibited dealings produces enormous cumulative liability.
Civil enforcement is strict-liability. OFAC does not need to prove you knew the counterparty was sanctioned. Not knowing is not a defense.
Criminal Penalties
Criminal exposure requires willfulness. A willful violation of IEEPA carries fines of up to $1,000,000 and imprisonment of up to 20 years for individuals.5Office of the Law Revision Counsel. 50 USC 1705 Penalties Willful violations of TWEA carry fines of up to $10,000 and imprisonment of up to 10 years.7Office of the Law Revision Counsel. 50 USC 4305 Penalties Separate penalties apply for recordkeeping and reporting failures, including fines of up to $73,011 per violation for failing to maintain compliance records.6Federal Register. Inflation Adjustment of Civil Monetary Penalties
Court Sanctions Against Lawyers and Litigants
Sanctions handed down inside a lawsuit are a separate category. A Rule 11 violation can mean a monetary fine payable to the court, an order to cover the opposing party’s attorney fees, or a nonmonetary consequence such as striking a filing or dismissing a claim.4Legal Information Institute. Federal Rules of Civil Procedure Rule 11 For a lawyer, these penalties also carry professional consequences that reach beyond the case at hand.
How to Tell Whether Someone Is Sanctioned
The main U.S. tool is OFAC’s Specially Designated Nationals and Blocked Persons List, usually called the SDN List. OFAC updates it frequently and on no set schedule.8U.S. Department of the Treasury. Specially Designated Nationals and the SDN List A free online search tool lets anyone screen names against the SDN List and the other lists OFAC administers.9U.S. Department of the Treasury. Sanctions List Search The Commerce Department’s International Trade Administration also publishes a Consolidated Screening List that combines export-control lists from several agencies.10International Trade Administration. Consolidated Screening List
A company does not need to appear on the SDN List itself to be blocked. Under OFAC’s 50 Percent Rule, any entity owned 50 percent or more in the aggregate by one or more blocked persons is automatically treated as blocked, even without a separate designation.11U.S. Department of the Treasury. Entities Owned by Blocked Persons 50 Percent Rule Stakes held by multiple sanctioned persons are added together, and ownership through intermediate holding companies counts. A company at 49 percent blocked ownership is not automatically caught by this rule, but OFAC can still designate it separately if it finds the entity is controlled by sanctioned persons.
Not Every Transaction With a Sanctioned Party Is Illegal
OFAC issues two types of authorizations that permit otherwise prohibited activity. A general license authorizes a defined category of transactions for a broad group of people without requiring anyone to apply individually, provided every condition in the license is followed.12U.S. Department of the Treasury. OFAC Licenses Humanitarian carve-outs for food, medicine, and medical devices often take this form. When no general license applies, a specific license can be requested in writing for a particular transaction, and OFAC decides case by case.13U.S. Department of the Treasury. OFAC Specific Licenses and Interpretive Guidance Any deviation from the license terms converts the authorized transaction into a violation.
Getting Off a Sanctions List
Being designated is not necessarily permanent. Any sanctioned person or entity can petition OFAC for removal by filing a written request for administrative reconsideration under 31 CFR ยง 501.807. The petition is submitted by email and should present evidence or argument showing that the designation was wrong or that circumstances have changed enough to justify delisting.14eCFR. 31 CFR 501.807
Petitions typically rest on one of three grounds: mistaken identity, factual error by OFAC, or changed circumstances such as cutting ties with the conduct that triggered the sanction. A petitioner can also offer remedial measures like corporate reorganization or the resignation of individuals whose involvement led to the designation. OFAC reviews the submission, often requests additional information, and issues a written decision.14eCFR. 31 CFR 501.807 There is no fixed timetable, and reviews often take months.
If OFAC denies the petition, the designated party can sue in federal district court under the Administrative Procedure Act. Courts review OFAC’s decision under an arbitrary-and-capricious standard, which requires the petitioner to show that OFAC failed to examine the relevant evidence or to give a reasonable explanation for keeping the designation in place.