Glossary
Snapback
A mechanism by which previously lifted sanctions are automatically reinstated if conditions are not met. It matters for diligence because relief can be reversed without a fresh negotiation.
A worked example and links to the primary regulators are added in Phase 2. For how this applies to a specific matter, a fixed-fee written position is the proportionate step.
Related terms
SDN vs sectoral sanctions The OFAC 50% Rule Ownership vs control (EU) EAR99 and ECCN