Sanctions screening for importers

Whether you must check your suppliers and customers against sanctions lists, what happens if you do not, and how to show afterwards that you did.

This page explains the obligation and how screening works. It is not legal advice, and no screening tool — including ours — can certify that a party is not sanctioned. Why that is, is explained below rather than hidden in a disclaimer.

The obligation

Do I have to screen my suppliers and customers? yes

Yes. EU sanctions regulations forbid making funds or economic resources available to listed persons and entities, directly or indirectly. That prohibition applies to every EU business, with no turnover threshold and no exemption for small importers.

There is no article that says "you must run a screening". What the regulations say is that you may not deal with listed parties — and in practice you cannot comply with that without checking. A breach does not require intent: paying an invoice to a listed counterparty is a violation even if you had never heard of the listing.

Three things people get wrong:

It is not only about the party you invoice. "Indirectly" covers ownership and control. A supplier that is 50% owned by a listed person is caught even though the supplier itself is not listed.
It is not a one-off. Lists change with every sanctions round. A party screened clean in January can be listed in March, and the check you did in January says nothing about the shipment you make in April.
Your bank screening is not your screening. Banks screen their own exposure, on their own timing, and they will not tell you what they found. That is not a defence.

Source: EU restrictive measures, e.g. Regulation (EU) 269/2014 Article 2 (freezing and no making available), and the equivalent article in each sanctions regulation. Checked: 3 September 2026.

Which lists do I need to check? scope

As an EU business the EU consolidated list is binding on you. The UN list matters because EU measures implement it, and the US OFAC list matters as soon as dollars, US persons or US-origin technology are involved anywhere in the chain.

List	Who publishes it	Binding on an EU business
EU consolidated	European Commission (DG FISMA)	Yes, directly
UN Security Council	United Nations	Via EU implementation
OFAC SDN	US Treasury	Not directly, but US-dollar payments and US-origin goods pull you in
UK, CH, national lists	Various	Only where you have that nexus

Checking only the EU list is the common shortcut and it is the one that hurts, because a dollar payment routed through a US correspondent bank brings OFAC into a transaction that looked purely European.

Source: the lists as published by the European Commission, the UN Security Council and OFAC. Checked: 3 September 2026.

How do I show afterwards that I screened? the real question

With a record that states which lists were searched, in which version, on what date, for which names and spellings, and what came out. A screenshot of a search box proves nothing, because nobody can tell what the list contained that day.

This is what an auditor, an accountant or a supervisor actually asks for, and it is where most screening falls apart. People screen diligently and keep nothing, or keep a result without the list version — which is the same as keeping nothing.

A usable record contains:

the lists searched and when each list was published, not just when you searched;
every spelling and transliteration that was checked, so it is visible what was and was not covered;
near matches and what you concluded about them — a screening with no near matches at all is usually a screening with the threshold set too high;
the date, kept with the transaction it belongs to.

Source: standard expectations under EU sanctions compliance and financial-crime supervision. Checked: 3 September 2026.

Why no tool can say "clean"

We built a screening tool and it will never tell you a party is not sanctioned. That is not caution for its own sake — it is what name-based screening can and cannot do.

Screening compares names. Names are transliterated differently from Arabic, Cyrillic and Chinese; companies trade under names that differ from their registration; people use patronymics, initials and married names. A search that finds nothing has established one thing only: these spellings did not appear in these lists on this date.

Anyone who turns that into "not sanctioned" is selling a guarantee they cannot honour. When it later turns out the counterparty was listed under a different transliteration, the buyer is holding a document that says the opposite — which is worse than holding nothing.

So our report says what was searched and what came out, shows near matches instead of quietly filtering them away, and leaves the judgement where it belongs: with you, and where it matters, with a lawyer.

What we check, and what it costs

Three official lists, refreshed daily, searched across every recorded spelling: the EU consolidated list, the UN Security Council list and OFAC SDN. Together roughly 26,000 listed parties and 73,000 name variants.

Every hit shows the ground for the listing — which regulation, which date, with a link to the official text — so you can read for yourself why a party is listed instead of taking a red flag on trust.

Level	What you get	Price
Check	One name, result on screen, with the ground for any hit. No record to keep.	Free
Record	PDF stating the lists, their publication dates, every spelling searched, all hits and near matches with your assessment field. This is the document you hand to your accountant.	€29
Monitoring	Your counterparties stay screened. You are told when a list changes in a way that affects them.	€29–99 per month

The free check gives you the answer. The paid levels give you the evidence. If you only need to know, the free one is enough — that is deliberate.

The screening tool is being finished. Want to be told when it opens, or need a screening done in the meantime? Use the form below.

What this does not cover

Ownership and control. A party can be caught because a listed person owns more than 50% of it, without appearing on any list itself. Establishing that needs company registers, not name matching.

Export controls and dual-use. A separate regime with its own lists and licences.

Adverse media and PEP status. Relevant for due diligence, but not sanctions.

Vessels, aircraft and goods. Sanctions also attach to ships, flights and specific products.

Where these apply, a specialist is the right answer rather than a tool. Several of the providers listed on this site do exactly this work.