Sectoral Sanctions
Sectoral sanctions restrict specific categories of transaction, typically new debt or new equity financing, with entities operating in named sectors of a targeted economy, without freezing their assets or barring ordinary commercial trade outright. The US version, the Sectoral Sanctions Identifications List, was created under Executive Order 13662 in 2014 following Russia’s annexation of Crimea, and its practical relevance has been substantially overtaken by the far broader blocking measures imposed after February 2022.
Key takeaways
- Sectoral sanctions restrict specific transaction categories, typically new debt or equity, without the full asset freeze the SDN List imposes.
- The SSI List was created under Executive Order 13662 (20 March 2014) in response to Russia’s annexation of Crimea.
- Four numbered Directives set the actual restrictions: Directives 1-3 cover debt/equity by sector, Directive 4 covers oil and gas project technology exports.
- The SSI List is legally separate from the SDN List, though the same entity can appear on both simultaneously.
- Russia’s 2022 invasion of Ukraine triggered far broader blocking sanctions that have substantially overtaken SSI’s original calibrated approach.
- Sectoral compliance is harder than SDN screening because restrictions live in Directive language, amended repeatedly since 2014, not a simple list match.
- General licences authorising wind-down activity are common for legacy exposure to newly restricted or escalated entities.
On this page
What sectoral sanctions actually doThe legal basis: Executive Order 13662The four Directives that actually set the rulesSSI vs SDN: not blocked, but often overlappingWhy SSI matters less than it used to: what happened after February 2022Other targeted lists beyond SSI and SDNWhy sectoral sanctions are genuinely harder to operationalise than SDN screeningGeneral licences and wind-down authorisationsBuilding sectoral sanctions into a compliance programmeFAQsRead more
20 Mar 2014
Date Executive Order 13662 created the sectoral sanctions framework
Source: The White House / OFAC
33%
Ownership threshold extending Directive 4’s technology export restrictions to related projects
What sectoral sanctions actually do
Sectoral sanctions restrict specific categories of transaction, most commonly new debt financing beyond a defined maturity or new equity investment, with entities operating in named sectors of a targeted economy. Unlike a full asset freeze, sectoral sanctions don’t block a listed entity’s property, don’t bar US persons from continuing to hold existing equity, and don’t prohibit ordinary commercial trade in goods and services with that entity. The restriction is narrow and specifically targeted at the transaction category the underlying order defines, not a blanket prohibition.
The legal basis: Executive Order 13662
The US Sectoral Sanctions Identifications List, the SSI List, was created under Executive Order 13662, signed by President Obama on 20 March 2014, in direct response to Russia’s annexation of Crimea and destabilising actions in eastern Ukraine. The order authorised the Treasury Secretary, in consultation with the State Department, to identify specific sectors of the Russian economy, energy, financial services, defence and related materiel, and metals and mining, and to prohibit defined categories of transaction with entities operating in those sectors.
The four Directives that actually set the rules
The SSI List itself doesn’t impose restrictions directly; the operative prohibitions sit in four numbered Directives issued under EO 13662. Directives 1, 2, and 3 restrict dealing in new debt beyond a defined maturity, often 14 or 30 days depending on the specific directive, or new equity, on behalf of designated Russian entities in the financial, energy, and defence sectors respectively. Directive 4 goes further, prohibiting the export or reexport by a US person of goods, services, or technology supporting deepwater, Arctic offshore, or shale projects, extending even to projects entirely outside Russia where a Directive-4-subject entity holds an ownership interest of 33% or more.
SSI vs SDN: not blocked, but often overlapping
OFAC is explicit that the SSI List is not part of the SDN List. An entity’s presence on the SSI List alone doesn’t mean its property is blocked or that US persons must sever all dealings with it; ordinary transactions outside the specific Directive’s restricted category remain permitted. That said, the same entity can independently also be designated as blocked under EO 13662 or another sanctions authority, in which case it appears on both lists simultaneously, with the SDN listing carrying the full blocking consequence and the SSI listing separately marking which sectoral Directive also applies to it.
Why SSI matters less than it used to: what happened after February 2022
This is the detail most existing SSI content hasn’t fully absorbed. Russia’s full-scale invasion of Ukraine in February 2022 triggered a dramatically broader sanctions response: Executive Order 14024 fully blocking major Russian banks outright, the G7 and EU’s coordinated price cap on Russian crude oil, and additional new-investment prohibitions under Executive Orders 14066, 14068, and 14071. This far more sweeping package has largely overtaken the calibrated, sector-specific approach the SSI framework was originally built around. Some analysts argue maintaining the SSI List alongside these much broader blocking measures now creates genuine compliance redundancy; others note the SSI categories still capture entities not yet escalated to full SDN status, preserving it as a graduated tool even in the current environment.
Other targeted lists beyond SSI and SDN
SSI isn’t the only non-blocking, sector- or activity-specific list OFAC maintains. The Foreign Sanctions Evaders List targets those helping Iran or Syria bypass restrictions, intermediaries arranging ship-to-ship transfers among them, requiring US persons to refuse business without automatically freezing assets unless the party is separately SDN-listed. The Non-SDN Iran Sanctions Act List names firms that invest heavily in Iran’s petroleum sector or supply it with key technology. Each of these, alongside SSI, forms part of the broader Consolidated Screening List that combines OFAC’s non-SDN data with equivalent lists from Commerce and State.
Why sectoral sanctions are genuinely harder to operationalise than SDN screening
Compliance teams consistently report that SSI compliance is more demanding than straightforward name-based SDN screening, precisely because the restriction lives in the Directive’s specific language, not the list entry itself. A firm has to understand exactly what each applicable Directive prohibits, track amendments to those Directives over time, since they’ve been modified repeatedly since 2014, and apply that understanding to the firm’s own specific activity, rather than simply blocking every transaction involving a listed name the way SDN screening effectively does.
General licences and wind-down authorisations
OFAC has issued numerous general licences specifically authorising wind-down activity connected to sectoral and broader Russia-related restrictions, letting firms unwind pre-existing positions or relationships over a defined period rather than facing an immediate, disruptive severance the moment a new restriction takes effect. Firms with legacy exposure to entities later added to the SSI List, or subsequently escalated to full SDN status, need to check for an applicable wind-down general licence before assuming immediate, total exit is the only compliant path.
Building sectoral sanctions into a compliance programme
A firm with genuine sectoral sanctions exposure needs controls that go beyond standard name screening: mapping which specific Directives apply to which categories of the firm’s own activity, tracking Directive amendments on an ongoing basis rather than treating the original 2014 scope as static, and layering sectoral checks on top of, not instead of, standard SDN and 50 Percent Rule screening, since a counterparty can trigger obligations under more than one of these frameworks simultaneously.
Map Directive-specific exposure, not just SDN matches
Check counterparties against sectoral restrictions layered on top of standard sanctions screening.
Frequently asked questions
What are sectoral sanctions?
Sectoral sanctions restrict specific categories of transaction, typically new debt or new equity financing, with entities operating in named sectors of a targeted economy, without freezing assets or barring ordinary commercial trade outright.
What is the SSI List?
The Sectoral Sanctions Identifications List, created under Executive Order 13662 in 2014 in response to Russia’s annexation of Crimea, identifying entities in Russia’s energy, financial, defence, and metals/mining sectors subject to targeted restrictions.
Is the SSI List part of the SDN List?
No. OFAC is explicit that the SSI List is separate from the SDN List, though the same entity can appear on both if it’s independently designated as blocked under EO 13662 or another authority.
What do the SSI Directives actually restrict?
Directives 1-3 restrict new debt beyond a defined maturity or new equity with entities in Russia’s financial, energy, and defence sectors. Directive 4 restricts export of goods, services, or technology supporting certain oil and gas projects.
Why has the SSI List become less central since 2022?
Russia’s 2022 invasion of Ukraine triggered much broader sanctions, including full blocking of major Russian banks and coordinated oil price caps, which largely overtook the SSI framework’s original calibrated, sector-specific approach.
Does the SSI List freeze an entity’s assets?
No. Unlike the SDN List, SSI listing doesn’t block property; US persons may continue holding existing equity and conducting ordinary trade outside the specific restricted transaction categories.
Why is sectoral sanctions compliance considered harder than SDN screening?
Because the restriction depends on the specific Directive’s language, which has been amended repeatedly since 2014, rather than a simple name match, requiring firms to map their own activity against each applicable Directive’s actual scope.
Are there other OFAC lists like the SSI List?
Yes, including the Foreign Sanctions Evaders List (targeting Iran/Syria sanctions evasion facilitators) and the Non-SDN Iran Sanctions Act List, both non-blocking, activity-specific lists similar in structure to SSI.
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Last reviewed July 19, 2026 · 11 min read · Written for compliance and risk professionals · By the WhoWiki editorial team
Key takeaway: Sectoral sanctions restrict specific categories of transaction, typically new debt or new equity financing, with entities operating in named sectors of a targeted economy, without freezing their assets or barring ordinary commercial trade outright. The US version, the Sectoral Sanctions Identifications List, was created under Executive Order 13662 in 2014 following Russia’s annexation of Crimea, and its practical relevance has been substantially overtaken by the far broader blocking measures imposed after February 2022.