OFAC Ukraine/Russia Sanctions Screening

Sanctions responding to Russia's actions in Ukraine, with comprehensive measures for Crimea and occupied regions and targeted measures for Donbas.

TL;DR

TL;DR: Ukraine/Russia sanctions combine comprehensive restrictions on Crimea and occupied regions with targeted designations for Donbas actors, and screening must reflect that split.

The program structure

The Ukraine/Russia sanctions program responds to Russia's actions in Ukraine. Crimea and the occupied regions are subject to comprehensive sanctions, meaning broad prohibitions on transactions involving those territories. The Donbas regions are handled through targeted measures aimed at specific actors rather than a full regional embargo. The distinction determines whether a transaction is barred outright or only when it touches a designated party. The split also means a compliance program must keep geography and list status distinct: a party can be barred by territory even with no individual designation.

Ownership and the 50 Percent Rule

Russian sanctions also rely heavily on the 50 Percent Rule: any entity owned 50 percent or more by a blocked person is itself treated as blocked, even without a separate listing. This makes ownership structure part of the screening question, not just a direct name match. Screening must therefore check both the counterparty's identity and the jurisdiction of the transaction.

Screening for agent payments

For agents paying across jurisdictions, sanctionsai.dev screens names and wallets against 16 jurisdictions including these programs. The screen returns ALLOW or BLOCK, and the 4-Gate protocol's STOP gate halts any payment that matches, so an autonomous flow does not route funds into a comprehensively sanctioned territory or to a designated Donbas actor.