How Government-Official Sanctions Work
The government-tier designation pattern, explained.
Overview
Government officials are often designated en bloc - a head of state, ministers, and senior officials on the same day under one authority. Putin, Lavrov, Mishustin, and Shoigu were designated together on February 25, 2022.
The pattern
- OFAC designates the leadership tier under a program authority
- State-owned entities follow (banks, defense firms)
- The 50% rule extends reach to entities they control
The screening shape
Screen the counterparty name, its owners, and its state-linked status. A payment to a Russian government entity is in scope - the government-entity scenario shows the workflow.
Why it matters
Government entities surface in supply chains, procurement, and state-linked vendors. The screen catches the named tier; ownership screening catches the shells.