This report by Observatoire ARGA and ARGA Atlas examines how international sanctions, compliance procedures, internal decisions by banks and digital platforms, and algorithmic risk assessments affect the rights of individuals and legal entities. It focuses on situations in which restrictive measures lead to asset freezes, denial of services, account closures, reputational harm and limitations on the right to effective legal protection.

The authors show that adverse consequences may arise even without formal inclusion in a sanctions list. Banks, payment systems, brokers, insurers, cryptocurrency platforms and analytics providers increasingly make independent decisions based on a risk-based approach. Although such decisions are formally private, their practical impact may be comparable to state-imposed restrictions on property rights and freedom of economic activity.

The report identifies key risks: opacity of compliance decisions, reliance on inaccurate or outdated data, automatic propagation of adverse risk profiles, de-risking practices and the persistence of restrictions after the original issue has been resolved. Particular attention is given to minimum procedural safeguards, including clear characterization of the measure, minimum reasoning, the right to submit explanations and evidence, human verification, proportionality, internal review and correction of data.

The report’s central conclusion is that sanctions and compliance can no longer be treated as a purely technical area of financial control. They require a distinct legal defense strategy aimed not only at challenging restrictions, but also at restoring access to financial infrastructure, correcting risk profiles and addressing reputational consequences.