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A name on the list: legal protection, errors and mistaken identity in targeted sanctions

· Helfen statt Blockieren editorial team

Most sanctions today hit not whole countries but names: people, companies, ships. Anyone on a list loses access to accounts and business, often without a trial. This article explains how one ends up on a list, how to fight it, how often that succeeds, and what applies when a bank mistakes a bystander for a listed person.

1,764people and companies were added by the US to its SDN list in 2025CNAS, 29 Jan 2026
105new sanctions cases at the EU General Court in 2025Court of Justice of the EU, statistics 2025
72 of 105completed requests to the UN Ombudsperson led to delistingUN, S/2025/195, as of 28 Mar 2025
0official counts of payments held because of name matchesown research, 3 Nov 2026

From country to name

After the experience of comprehensive embargoes, such as on Iraq in the 1990s, states and the United Nations developed targeted sanctions in the so-called Interlaken process. As political scientist Maria J. Debre describes it, they are meant to hit populations less and address governing elites directly. In its 2004 basic principles the Council of the EU required sanctions to be targeted at those whose behaviour is to be influenced and humanitarian effects to be avoided as far as possible.

The lists are growing fast. The data company Castellum.AI counts more than 11,200 new listings worldwide for 2025. According to the Center for a New American Security, the United States added 1,764 people and companies to the Specially Designated Nationals (SDN) list in 2025, 1,322 under the new and 442 under the outgoing administration; in 2024 it was 3,135, in 2022 2,275. About three quarters of the additions under the new administration concerned networks around Iran. It removed 38 Russia-related entries.

A listed person’s assets are frozen; no one may make money or goods available to them. No criminal judgment is needed. Supporters see this as the advantage of targeted sanctions: they act quickly, hit those responsible and spare the population. Critics see punishment without trial, in which those affected often do not know the evidence. Both views have occupied the courts.

Legal protection in the EU

The turning point was the Kadi judgment of the Court of Justice of the EU of 3 September 2008. Saudi businessman Yassin Abdullah Kadi and the Al Barakaat foundation were on a UN list that the EU had taken over. The Court ruled that even when the EU implements a Security Council decision, its courts must review whether fundamental rights are respected. Because the grounds had never been communicated to those affected, it found the rights of defence and to effective judicial review violated and annulled the listing; the Council was given three months to remedy the defects.

Since then anyone listed by the EU can sue before the General Court in Luxembourg. The official statistics show how sharply the number has risen since Russia’s attack on Ukraine: 42 new cases in 2021, 103 in 2022, 63 each in 2023 and 2024, and 105 in 2025. In 2025 the General Court registered 989 new cases in total, more than ever.

Sanctions cases at the EU General Court

Cases on “restrictive measures”, newly brought and completed per year.

Yearnewcompleted
20214256
202210332
20236369
20246388
202510571

Source: Court of Justice of the EU, statistics on the judicial activity of the General Court 2025, tables IV and XII, accessed 3 Nov 2026.

A EUobserver report of September 2026 cited, according to a lawyer, 125 new sanctions cases in 2025, 84 of them Russia-related, and legal costs of up to 500,000 euros per case. The official statistics do not confirm the figure of 125; they count 105. The costs rest on a lawyer’s statement and are not officially documented.

Suits sometimes succeed, but not always for good. On 10 September 2025 the General Court annulled the renewals of September 2024 and March 2025 of the listing of Russian businessman Dmitry Pumpyansky; it had already annulled an earlier listing in June 2024, after which the Council relisted him on new grounds. The Council can therefore correct itself. For those affected this means that a judgment won does not mean the account is free again.

Legal protection at the United Nations

There is no court against Security Council lists. For the ISIL and Al-Qaida list, the Council created the Office of the Ombudsperson in 2009 with Resolution 1904; it reviews requests independently and reports to the committee. According to its report of 28 March 2025, it had accepted 112 requests since its creation and completed 111, 105 of them through the full procedure; 72 led to delisting, 33 were rejected. 67 individuals and 28 entities were delisted.

For all other UN lists, such as those on North Korea, Libya or Yemen, there is only a focal point that receives requests; decisions are taken in the relevant sanctions committee, made up of the members of the Security Council. According to UN statistics of 15 May 2026, it had received 125 requests; 20 individuals and 17 entities were delisted. There is no independent review there as with the Ombudsperson; that is the difference, and the states in the Security Council have not changed it so far.

Mistaken identity: when the bank holds the wrong person

Banks automatically screen every payment against the lists. A name resembling a listed name can be enough for a transfer to be held or an account to be reviewed. How often this hits bystanders is not known: we found no official figure at the EU or German authorities. We therefore give no estimate. This website publishes documented cases only with the written consent of those concerned.

When a bank closes accounts altogether because it considers a country or customer group too risky, this is called de-risking, covered in “Banks and de-risking”. How a permitted payment still gets stuck is shown in “Why a permitted payment gets stuck”.

And Cuba?

Cuba is a case for both forms. The US embargo is comprehensive and hits the whole country; at the same time the US State Department keeps a list of Cuban entities with which US persons may not do business. On the other side, Prisoners Defenders counted 1,351 political prisoners under the Cuban leadership (September 2026). In 2025 the United States also imposed visa restrictions on President Díaz-Canel and other officials and expanded the list of restricted Cuban companies. Whether that works is disputed; more in “Do sanctions work?” and “Cuba: human rights and political prisoners”.

This article is information, not legal advice. It relies on the sources listed; where experts disagree, it names the positions and who holds them. “Helfen statt Blockieren” is non-partisan.

Sources

All online sources accessed on 3 November 2026.

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