What is the difference between EU, UK and US sanctions?

EU, UK and US sanctions are legally distinct regimes with different designation criteria, review procedures, and enforcement mechanisms. Following Brexit, UK sanctions no longer automatically mirror EU lists — the UK maintains its own OFSI-administered regime. US OFAC sanctions are extraterritorial in scope and can affect non-US companies. Being listed in one regime does not automatically mean designation in another, but coordinated multi-regime exposure is increasingly common for high-profile clients.