Sanctions screening

Sanctions screening is the process of checking customers, supply-chain parties, intermediaries, counterparties, documents, and transactions against official sanctions lists to identify prohibited locations, parties, or dealings. It is a core control within risk-based sanctions compliance programmes used by banks active in export finance, project finance, and commercial real estate.

How sanctions screening is used on EF, PF and CRE desks

Desks screen borrowers, sponsors, guarantors, ultimate beneficial owners, agents, offtakers, and other deal parties at onboarding and on an ongoing basis. Export finance files often touch multiple jurisdictions and correspondent rails, so list coverage and ownership rules matter as much as the name match itself: designations extend to entities owned or controlled by listed parties, so a borrower that appears clean on its own may still be ineligible through a parent or controlling shareholder. Project finance and CRE facilities add long tenor and layered SPV structures, which widens the set of related parties that sit inside KYC and customer due diligence.

Screening is not a standalone product decision. It sits beside ownership look-through, licence analysis, and escalation to compliance when a potential match requires human review.

Institutional lists and programme mechanics

Major list regimes include:

• United States. The Office of Foreign Assets Control (OFAC) administers and enforces US economic and trade sanctions. OFAC publishes the Specially Designated Nationals and Blocked Persons (SDN) List and other sanctions lists, and provides a Sanctions List Search tool. OFAC's Framework for OFAC Compliance Commitments sets out five essential components of a risk-based sanctions compliance programme: management commitment, risk assessment, internal controls, testing and auditing, and training. Screening of customers, intermediaries, counterparties, documents, and transactions is part of those internal controls, including timely list updates and attention to alternative spellings and identifiers.
• United Kingdom. Designations under the Sanctions and Anti-Money Laundering Act 2018 appear on the UK Sanctions List. From 28 January 2026 the UK Sanctions List is the sole official source for UK sanctions designations, spanning financial, immigration, trade and transport measures; the former OFSI Consolidated List of asset-freeze targets is no longer updated.
• European Union. EU restrictive measures are a Common Foreign and Security Policy instrument. The European Commission maintains consolidated financial sanctions data to support asset-freeze compliance across Member States.

The main sanctions lists differ in scope and update mechanics. True matches, near matches, and ownership or control linkages require documented disposition. A name hit alone is not a determination; programme rules govern investigation, blocking or rejection, licensing, and reporting where required.

Distinctions from related controls

Sanctions screening tests parties against binding list and programme prohibitions. Adverse media screening reviews public reporting on alleged or proven misconduct that may not appear on a sanctions list. Both inform financial-crime risk assessment under standards associated with the FATF, but they answer different questions and generate different escalation paths.