Sanctions screening for 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.

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.

This is the gap that catches traders, and it is a real one rather than a theoretical one. The UK has designated a large number of intermediaries; freight forwarders, trading companies and free-zone entities in the Gulf; connected to the Russian energy trade that the EU has not listed. Screening only the EU list returns nothing for those parties.

What actually happens then:

• The bank moves first. Dutch banks run their own screening against the UK list among others, and their financial-crime teams contact the customer directly about counterparties they have already invoiced.
• It is retrospective. A party you dealt with lawfully in August can be designated in October. That is not a breach on your side, but you will be asked to explain the relationship, and the answer has to be documented.
• Onboarding stalls. A new account application can sit on hold for weeks while this is worked through, which costs more in practice than the sanction ever would.

So the UK list is in our check not because it binds you, but because leaving it out produces exactly the false reassurance this page warns against. A search that says nothing while your bank is about to call is worse than no search.

Two different things get conflated, and the difference matters for what you can screen against:

• The sponsors-of-war list is gone. It was a reputational blacklist of companies still doing business in Russia, maintained by the anti-corruption agency NACP. It named multinationals, several governments objected, and the portal was closed in March 2024. Anyone still offering "Ukraine sponsors of war screening" in 2026 is screening against a list that stopped existing; worth knowing before you pay for it.
• The State Register of Sanctions is real and current. At drs.nsdc.gov.ua the NSDC publishes every Ukrainian sanction with the presidential decree behind it: roughly 9,650 legal entities, 13,800 individuals and 870 vessels, updated as decrees are issued.
• It is not binding on an EU business; the UK-list logic in reverse. Ukrainian sanctions apply in Ukraine. For an EU importer they matter commercially: for anyone selling into Ukraine or buying Ukrainian assets, and because Ukrainian designations; especially on shadow-fleet vessels and on suppliers routing goods to Russia; have repeatedly been ahead of EU and UK listings.

The check on this page searches the Ukrainian register alongside the other lists; the list-status line above the form shows when its version was last loaded. The register itself stays public and free to search directly.

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.

What that looks like in practice: you deal with a counterparty in August under a screening that shows nothing, because at that moment there was nothing to show. In October a designation follows. You did not breach anything; but your bank now has a listed party in your payment history, and you will be asked to explain the relationship.

Three things follow from that:

• Screen per transaction, not per counterparty. January’s result says nothing about April’s shipment.
• Keep the dated record. When a party is designated later, the document showing you checked at the time is the difference between an explanation and a problem.
• Watch the ones you keep dealing with. That is what monitoring is: your counterparties are re-screened against every list every day, and you hear from us only when something changes; a new listing, a lifted one, or a new near match.

The distinction matters because most people keep the wrong thing. Knowing the answer and being able to prove you knew it are separate problems, and the second one only becomes visible months later, when someone asks.

A record is worth buying at the point where a transaction carries real money, where an audit or a bank review is foreseeable, or where the counterparty is new and you have nothing else on file. For a supplier you have used for ten years and screen out of routine, the free check is enough, and saying so costs us the sale.

What the answer means depends on what comes back:

• A MATCH means the exact spelling appears on a list. Read the ground before anything else: which regulation, which annex, what it actually prohibits. Not every listing is a payment ban; some are supply bans or sector measures.
• ASSESS means a near-match on a close spelling. Compare date of birth, country and registration numbers before concluding it is a different party. A typo in a supplier name is exactly how a sanctioned party slips through.
• NO HIT means these spellings did not appear in these lists on this date. That is not the same as: not sanctioned. Ownership above 50% by a listed person is invisible in a name search, and lists change with every round.

What is deliberately free here and what is not:

• The answer is free: on screen, with the ground for every hit, including near matches.
• The evidence costs money: the dated record that states which list versions were searched, every spelling checked and all near matches, for an auditor or a bank.
• The watching is money: your counterparties re-screened against every list every day from EUR 9 a name per month, mail only when something changes.

There is no free lunch elsewhere either: "free" screeners that store your searches are building a database of who you deal with. This check sends the name to the search and keeps nothing.

A pre-payment routine that holds up:

1. Screen the payee name against the lists (free, above). Also screen the bank account holder if it differs from the supplier; payment to a third account is where fraud and sanctions exposure meet.
2. Verify the VAT number in VIES and keep the response (verify page, free).
3. Re-screen per transaction, not per relationship. A party screened clean in January says nothing about a payment in April; designations land every month.
4. Keep the dated evidence. A screenshot of a search box proves nothing because it does not show which list version was searched; that is what the dated record is for.

Paying a listed party does not require intent to be an offence, and "the supplier gave me a code" is not a defence. The routine above takes about a minute per invoice.

Two directions from here:

• Probably a name coincidence? Compare date of birth, country, registration number and address from the listing with your counterparty. If they differ, write down that comparison with the date; that is your documented false-positive assessment.
• It is really your counterparty? Follow what to do after dealing with a sanctioned party: freeze what you hold, document everything, and take legal advice before you talk to anyone; the order matters and panicking the money back is a second violation.

Your bank will screen the payment anyway. A payment to a listed party that is stopped by the bank freezes a shipment already at sea and puts the relationship in a review you did not choose. Screening before paying is cheaper than explaining after.

What people underestimate is the second-order damage. Long before any penalty:

• Your bank acts first. Banks screen their own exposure continuously. A payment stopped mid-transaction freezes a shipment already at sea, and the bank will not explain what it found.
• Your own customers ask. Scheme audits and larger buyers increasingly ask what screening you run and to see it. An answer of "we look at the news" ends conversations.
• The file is reconstructed afterwards. When something does surface, the question is never "did you know" but "what did you have in place". That is a documentary question, and it is answered from what you kept.

This is why the record exists as a product at all. The screening is cheap and the lists are public; what is scarce is a dated, list-versioned statement of what was searched.