Debarment and warning lists
Sanctions, debarment and PEP status compared
Short answer
- Sanctions effect (OFAC)
- Block property or reject prohibited transactions 1
- World Bank debarment baseline
- 3 years with conditional release 4
- US federal debarment period
- Should not exceed 3 years in most cases, with stated exceptions 5
- FATF PEP guidance
- June 2013 6
- EU former PEP period
- At least 12 months after leaving office 7
Three different records
A sanctions listing is made by a government or the UN. OFAC's screening guidance tells firms to block property where required and reject prohibited transactions where no blocked person is involved 1. Removal goes through a delisting petition 2.
A debarment is a procurement exclusion. The World Bank list names parties ineligible for World Bank-financed contracts for the periods shown 3. In US federal contracting, agencies shall not solicit offers from or award contracts to excluded contractors 5.
PEP status is a customer risk label used under anti-money laundering rules. FATF defines a PEP as an individual who is or has been entrusted with a prominent public function 6.
Side by side
| Feature | Sanctions listing | Debarment | PEP status |
|---|---|---|---|
| Legal effect | Block or reject dealings 1 | Ineligible for contracts 3,5 | Enhanced due diligence by banks 6 |
| Who decides | Government agency such as OFAC 2 | Bank sanctions bodies 3 or agency debarring officials 5 | Firms take reasonable measures to determine status 6,7 |
| Finding of wrongdoing | Listing criteria under each regime 2 | Sanctionable practice or cause for debarment 4,5 | None implied 6 |
| How it ends | Delisting petition 2 | End of period or release on conditions 4 | Risk-based, no fixed time limit in FATF guidance 6 |
Debarment in more detail
The World Bank's baseline sanction is a 3-year debarment with conditional release 4. Lighter outcomes include a letter of reprimand and conditional non-debarment 4.
Under FAR subpart 9.4, debarment and suspension are discretionary and are meant to protect the government's interest, not to punish 5. Debarment periods should not exceed 3 years in most cases, with stated exceptions 5. A suspension ends if legal proceedings do not begin within 12 months, subject to a 6-month extension, and cannot pass 18 months without proceedings 5. Exclusions are recorded in the System for Award Management 5.
PEP status in more detail
FATF guidance from June 2013 covers foreign PEPs, domestic PEPs, international organisation PEPs, family members and close associates 6. For foreign PEPs, it calls for senior management approval, reasonable measures to establish source of wealth and source of funds, and enhanced ongoing monitoring 6. For domestic and international organisation PEPs, enhanced measures apply to higher risk relationships 6.
The EU definition lists heads of state, ministers, members of parliament, senior judges, central bank board members, ambassadors and others. It excludes middle-ranking or more junior officials 7. EU firms must keep applying risk-based measures to a former PEP for at least 12 months 7. FATF says handling a former PEP should rest on risk, not on prescribed time limits 6.
Warning lists are a fourth category
Regulator warning lists are separate again. The FCA Warning List names firms the FCA is concerned are working without its permission 8. The FCA describes it as its list of unauthorised firms and individuals 8.
Common questions
Is a PEP the same as a sanctioned person?
No. FATF says being a PEP does not prejudge a link to criminal activities 6.
Does a World Bank debarment freeze a company's assets?
The World Bank list records ineligibility for World Bank-financed contracts 3. Asset blocking is a sanctions measure 1.
How long does someone stay a PEP?
In the EU, risk-based measures continue for at least 12 months after the person leaves office 7. FATF guidance sets no fixed time limit 6.
How long does a US federal debarment last?
FAR says it should not exceed 3 years in most cases, with exceptions 5.
Rules and charges change. Check the official source linked on this page before you pay or travel. Spotted an error? Email hello@sanctionslistsexplained.com.
Sources
- Office of Foreign Assets Control: When screening for sanctions, how do I determine if I have a valid match to a name on one of OFAC's lists? (FAQ 5, updated 9 September 2026)
- Office of Foreign Assets Control: How to Request Removal from an OFAC Sanctions List
- World Bank: World Bank Listing of Ineligible Firms and Individuals
- World Bank Group: WBG Sanctioning Guidelines (31 October 2024)
- Acquisition.GOV: Subpart 9.4, Debarment, Suspension, and Ineligibility
- FATF: FATF Guidance: Politically Exposed Persons (Recommendations 12 and 22) (June 2013)
- EUR-Lex: Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (20 May 2015)
- Financial Conduct Authority: FCA Warning List of unauthorised firms (last updated 30 June 2026)
Related
- What a sanctions listing means
What a listing on a UN, US, EU or UK sanctions list does, who decides it, how owned companies are treated and what routes exist to ask for removal.
- World Bank and multilateral development bank debarment
How the World Bank Group sanctions firms and individuals, the sanction types, its ineligibility list and cross-debarment among development banks.
- Regulator warning lists and clone firms
How regulator warning lists work in the UK, US and Singapore, what a clone firm is, what a listing means and the IOSCO I-SCAN database.
- False positives and name matching in sanctions screening
Why screening flags innocent names, how OFAC's search scores matches, the review steps OFAC suggests and official routes for people wrongly matched.