In a practical sense, isn’t freezing the assets in Scenario A a more forceful way to accomplish the goals of sanctions policy, even if the transaction can get accomplished through some other means – by creating immediate real-world economic consequences for the failed attempt that even reporting on attempted transactions just can’t measure up to?

This is the crux of it, and the sharpest way to answer is: forceful against whom?

Walk through what actually happens to the designated person under each model

In Scenario A, freeze and reject produce the identical outcome for the sanctioned party: they don’t get paid, either way. They’re equally free, either way, to go find the same money — or different money — through Beijing or Istanbul. Freezing the funds doesn’t touch anything the designated person owns, because as established previously, nothing was theirs yet. So the marginal “forcefulness” being described isn’t landing on the sanctions target at all. It’s landing on Customer A — the non-designated party whose money actually gets locked away, indefinitely, based on nothing more than their instruction to pay someone.

That’s a real distinction worth sitting with: freezing in Scenario A is expropriating an unadjudicated third party’s property because of what they attempted, not punishing the person the sanctions regime actually targets.

But there’s something real here too

There is a genuine difference between freeze and reject that survives this reframing, and it’s not nothing: reject hands Customer A their money back, fully unencumbered, free to try the exact same payment again five minutes later through a different bank — the “ammunition” is untouched. Freeze removes that specific pool of liquidity from anyone’s use entirely. If the underlying deal is going to happen at all now, it needs fresh capital, not this capital. That’s a real cost, and it’s the honest, defensible case for the US approach here — it just achieves that cost by seizing the property of someone who hasn’t been found to have done anything wrong, rather than the property of someone who has.

And the EU-family model doesn’t actually leave the attempt costless — it just sequences the cost differently

If Customer A knowingly tried to pay a designated person, that attempt is itself a prosecutable sanctions offense in every jurisdiction covered — participating in or facilitating a breach of the making-available prohibition carries real civil and often criminal penalties, frequently well beyond the value of the blocked transaction itself. So both models are capable of imposing a serious, real cost on Customer A specifically. The difference is procedural: OFAC’s block is automatic and immediate, applied the instant the instruction is given, regardless of whether Customer A knew anything about the designation. The EU-family model waits for an investigation to actually establish knowledge or intent before it converts “you tried this” into a penalty. One bets on speed and volume (freeze everything that touches you, sort out culpability later, if ever); the other bets on accuracy (don’t touch anyone’s property until you can show they did something wrong).

So a gentle pushback on “even reporting can’t measure up” — reporting isn’t the alternative to a real economic consequence, it’s the on-ramp to one. It’s slower and it requires someone to actually build the case. Whether that trade-off is worth it depends on how much you weight “we caught more bystanders along with more real violators, faster” against “we only touched people we could actually show did something wrong.” That’s a genuine values question in sanctions design, not a case of one side simply declining to try.