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Parameter OFAC SDN List UK Consolidated List Administrator OFAC / U.S. Treasury OFSI / HM Treasury Entries ~15,000+ ~4,000+ Legal basis IEEPA / Executive Orders SAMLA 2018 / Statutory Instruments Civil liability standard Strict liability Strict liability (from 2022) Challenge mechanism Reconsideration Petition; Federal Court Ministerial Review; Administrative Court Russia overlap post-2022 Significant Significant

License Previous Version Updated Version Key Changes GL 46B GL 46A GL 46B Narrowed counterparty scope; revised wind-down conditions; SDN carve-out clarified GL 48A GL 48 GL 48A Expanded reporting obligations; adjusted permitted activity list; intermediary obligations added GL 49A GL 49 GL 49A Stricter subcontractor due diligence; additional infrastructure service conditions

United Nations (UN) European Union (EU) United Kingdom (UK) Source Resolutions of the UN Security Council (UNSC) Decisions of the EU Council, implemented through EU Regulations, which have direct effect in all 27 member states. After Brexit, the United Kingdom introduced its own autonomous sanctions regime, administered by the Office of Financial Sanctions Implementation (OFSI) […]