Before my PhD I worked in sanctions compliance. To add to the chatter about today's ICC sanctions, here's a thread about how lives are destroyed when someone is listed by OFAC.

When someone is added to the list, their name and info are added to screening products used by every major bank, and many MNCs, with US ties.

Depending on the screening product, analysts may conduct research on any relatives, associates, businesses, and even charities associated with the SDN, and also add them to the screening list.

Many of these unlisted entities and individuals will experience the full catastrophic effects of being listed.

These effects can extend to basic service access.

Health insurance companies have been fined for not revoking the existing health insurance policies of the family members of newly listed SDNs.

Banks have an incentive to over screen— in most cases potential losses are much larger than potential gains.

Even small banks without direct US ties may be compelled to comply because of fear of losing correspondence banking relationships, or of being sanctioned themselves. Those impacted cannot simply turn to local banks.

The effects of being being sanctioned as an individual are immense, and almost entirely mediated in scope and duration by private sanctions compliance services.

To conclude my rant, sanctions like today’s have immense symbolic, political, and individual effects.

We should consider why the listing and delisting process is so opaque, and the implications of the private sector mediating sanctions impact.