How to Check Sanctions

Sanctions screening is the process of checking whether the people and organisations you deal with appear on government sanctions, export control, or restricted party lists. In most jurisdictions, you are expected to screen before entering into a transaction or relationship — and to keep a record that you did so. This guide walks through how to perform a sanctions check and, critically, how to document your findings — whether you find a match or not.

Step 1: Understand why screening matters

• US (OFAC) — strict liability applies. Violations can result in penalties even without knowledge or intent.
• EU — restrictive measures are updated frequently and apply to all EU persons and entities.
• UK (OFSI) — strict liability applies to financial sanctions breaches.
• Australia (DFAT) — autonomous sanctions and UN Security Council measures are enforced domestically.

Universities, research institutions, exporters, financial institutions, and any organisation with international dealings may have screening obligations. Even where not strictly required, screening and documenting your checks demonstrates good faith due diligence.

Step 2: Identify who to screen

• Counterparties — customers, suppliers, partners, vendors
• Beneficial owners — individuals who ultimately own or control an entity
• Intermediaries — agents, brokers, or third parties involved in a transaction
• Vessels and aircraft — relevant for shipping and trade
• Research collaborators — visiting scholars, co-investigators, and collaborating institutions

The scope depends on your risk profile. Higher-risk transactions (cross-border, high-value, or involving sanctioned jurisdictions) warrant broader screening.

Step 3: Know which lists to check

Most organisations with cross-border exposure should screen against multiple lists. A consolidated screening tool saves time by searching all relevant lists simultaneously.

Step 4: Prepare your search terms

• Full legal name (and any known trading names or abbreviations)
• Known aliases or alternative spellings — especially for names transliterated from non-Latin scripts
• Country of origin or incorporation — useful for narrowing results

Step 5: Run the search

• Start with a broad search — this catches spelling variations, transliterations, and partial matches that exact matching would miss
• Search aliases separately — don’t rely on the primary name alone
• Toggle PEP lists on or off depending on whether your compliance requirements include Politically Exposed Persons screening

A search that returns no matches is still a valuable result — it forms the basis of your “no match” documentation.

Step 6: Review your results

If you get no matches: This is the outcome for the majority of checks. A timestamped “no match” record demonstrates that screening was performed and nothing was found at that point in time. Add the result to your checklist so you have a permanent record.

If you get matches: Review each result carefully. Compare the listed entity’s details (nationality, entity type, designation source) against what you know about your counterparty. Not every match is a true match — common names generate false positives. Click into an entity profile to see official source data and related entities via Wikidata enrichment.

Step 7: Build your checklist report

• Add no-match searches — when no list match is found, add the “no match” result to your checklist. This records that you searched the name, which lists were checked, and that nothing was found.
• Add list matches — if a match was found, add it so you can document your assessment and any notes.
• Label the checklist — add an arrangement title or reference number so the report is easy to retrieve later.
• Add notes — record any context or reasoning behind your assessment.

Once your checklist is complete, export it as a timestamped PDF report. This creates a permanent, dated record of your screening — the kind of documentation regulators and auditors look for. The PDF includes every entity you checked (with match status and timestamps), every data source that was searched, and when each source was last updated.

Step 8: Set up ongoing monitoring

• Add counterparties to your watchlist for daily monitoring — you will be notified if their sanctions status changes
• Rescreen periodically when lists update or when circumstances change
• Monitor for delistings — a previously sanctioned party may have restrictions lifted, which could affect your business decisions

Common screening mistakes

• Screening only once — lists change constantly. A one-time check at onboarding is not ongoing compliance
• Exact-match only — name variations, transliterations, and spelling differences mean exact matching misses real hits. Broad matching is essential, especially for names transliterated from Arabic, Cyrillic, or Chinese scripts
• Ignoring the 50% Rule — under OFAC rules, entities owned 50% or more by blocked persons are themselves blocked, even if they do not appear on the SDN List by name
• Checking only one list — OFAC alone is insufficient if you have EU, UK, or other international exposure
• No records — if you can’t prove you screened, you effectively didn’t. Undocumented screening provides no mitigation in an enforcement action
• Over-relying on your bank — your bank screens its own transactions, but that does not relieve you of your independent obligation to screen your counterparties and supply chain

What is a consolidated screening list?

A consolidated screening list combines multiple government lists into a single searchable database. The US government provides an official Consolidated Screening List (CSL) at trade.gov, combining lists from the Departments of Commerce (BIS), Treasury (OFAC), and State. However, the CSL covers only US government lists — no EU, UK, UN, Australian, Canadian, or Swiss data — and provides no documentation, reporting, or audit trail.

Third-party tools like Sanctions Checklist go beyond the CSL by aggregating US lists alongside international sanctions data in a single search. This eliminates the risk of missing a designation on a list you didn’t think to check. Our comparison page breaks down how different providers approach this.