How does the EU/UK sanctioned-countries list differ from the OFAC list?

The three regimes overlap heavily but are legally independent — a country or entity restricted by OFAC does not automatically appear on the EU or UK lists, and vice versa. OFAC’s Specially Designated Nationals and Blocked Persons List is maintained by the U.S. Treasury under IEEPA and updates on a rolling, unscheduled basis, sometimes with dozens of designations in a single week. The EU Consolidated Financial Sanctions List is built from Council Regulations requiring unanimous agreement among all 27 member states and is published in batched packages through the Official Journal of the European Union, typically weeks apart. Since Brexit, the UK runs its own UK Sanctions List on a separate cadence entirely. The legal effect differs too: an OFAC SDN designation triggers full asset blocking for U.S. persons, while some EU and UK measures apply narrower restrictions such as travel bans or sectoral debt/equity limits without full blocking.