What you get
Look at a record first
— a real one, with the client name replaced and the counterparties
that are not on a list renamed. The listed parties in it are real and
public. It is the whole document, not a sample page.
A record of what changed the point of it
Each round is compared with the previous one, and the
document opens with the difference: which counterparty is now
on a list that was not before, and which has been delisted. If nothing
changed, it says so — dated. That sentence is worth having too: it
is what you show when someone asks whether you were watching.
Method: every name is rescreened in full against
the current list versions; the comparison is against the stored result of
the previous round, not against a cached answer. Checked: 4 September 2026.
A dated document, not a dashboard
Reference number, timestamp, the six lists with their
version and the number of parties and spellings in each, then the findings
per counterparty with the ground each listing rests on. Print it, file it,
attach it. Near matches get their own section with an empty assessment box
— that judgement is yours to make and to sign.
Lists: EU (DG FISMA), UN Security Council, OFAC
(US), UK (FCDO), Switzerland (SECO), Canada — the same six behind the
free tool. Checked: 4 September 2026.
The finding a name search misses ownership
A counterparty can be on no list at all and still be
caught, because it is owned or controlled by a party that is
listed. Searching its name returns nothing. The record has a separate
section for this: linked to a listed party, naming the
relationship and the listed entity behind it. On a test run of twenty
names, five had such a link and one of those had no hit of its own
— it would have passed a name check unnoticed.
Source: Regulation (EU) 269/2014, Article 2
(ownership and control). We report the link; establishing the actual
percentage is yours. Checked: 4 September 2026.
What it never says read this one
“Clean”, or “not sanctioned”.
No name gets that, ever. A name without a hit is recorded as
no match on these lists on this date, which is a different
statement. Lists outside the six are outside scope, a link we report is
not proof of the 50 percent threshold being met, and a screening says
nothing about the day after.
Source: Regulation (EU) 269/2014, Article 2;
list versions as published on the date of the record.
Checked: 4 September 2026.
Getting it
Send the list of counterparties — a spreadsheet column is enough
— and you get the first record back, dated, before anything is agreed.
That way you see the document before you decide, which is the only sensible
order for something you are meant to file.
Ask about screening
See a record first
Or write to
bart@importrules.com with the
number of counterparties. You get a number the same day.