**Abstract**

This article is devoted to the analysis of models of sanctions compliance in different countries. In the first part, I discuss the definition of sanction compliance. Concept compliance is an institution of private law, it is a mechanism (function, system, and culture) of self-regulation for companies, and the methodology of compliance risk management is based on a risk-based approach stemming from different corporate governance and culture. A comparative methodology is based on three criteria: 1) principles of compliance; 2) the ability to interact with regulators and the ability to exclude themselves from sanctions (delisting); and 3) methods of appeal. In paragraph 1.2, I concisely describe models under the above-mentioned criteria of sanctions compliance in the US, the UK, the EU, Germany, and Russia. I carry out a comparative analysis of various models. Each of these models of sanctions compliance has its own specifics.

**Keywords:** sanction compliance, regulation, interaction, regulatory expectations, countersanctions
