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Sanctions screening

Screen a name against the consolidated sanctions lists we ingest. A clear result is not legal advice — always confirm against the source list before acting.

✓ No match for “PATHWAY TRUST” on the lists we hold.

What sanctions screening does, and where it stops

A sanctions list names people, companies, vessels and aircraft that a government has designated. The consequences are strict and they are criminal: assets frozen, funds and economic resources withheld, dealings prohibited. They apply whether or not you knew — which is why screening a counterparty before you contract with them is ordinary commercial hygiene rather than a specialist exercise.

Three lists are screened here. The UK list is maintained by OFSI at HM Treasury and is the one that binds UK persons. The OFAC list reaches far beyond the United States, because it follows the dollar and the US financial system. The EU list matters wherever an EU entity or euro clearing is in the chain. A name can appear on one and not the others, and the regimes behind them differ.

The hard part is not the list, it is ownership. Sanctions bite on entities more than 50% owned or otherwise controlled by a designated person, and those entities are not themselves named. That is why a screen is the beginning: look up the counterparty, read who controls it, and screen those names too.

Frequently asked questions

Which sanctions lists does this screen against?▾
Three consolidated lists: the UK list maintained by the Office of Financial Sanctions Implementation, part of HM Treasury; the US list of Specially Designated Nationals and Blocked Persons maintained by OFAC; and the EU consolidated list. Each hit says which list it came from and under which regime the designation was made.
Why does it return possible matches rather than a yes or no?▾
Sanctions lists write names as the designating authority received them — transliterated from another alphabet, in a different order, with or without a patronymic. A screen that demanded an exact string would clear a designated person because their name was typed the ordinary way round. Every word of the query is matched anywhere in the recorded name, which finds the person and also finds their namesakes. Judging between them is yours to do, against the source list.
Does a clean result mean it is safe to trade?▾
No. It means no name on the three lists we hold matched what you typed. It says nothing about ownership — an unlisted company can be more than 50% owned or otherwise controlled by a listed person, and dealing with it is caught in the same way. It says nothing about export controls, sectoral measures, or lists we do not hold. This is a first filter, not a compliance decision, and it is not legal advice.
How often are the lists reloaded?▾
Daily. Designations are added and lifted in batches, so a screen run today reflects the lists as they stood at the last load. Before acting on a result — in either direction — confirm it against the publishing authority’s own list, which is the only version that governs.
What are my obligations if there is a match?▾
UK financial sanctions bind every person in the UK and every UK person abroad. Where funds or economic resources belong to a designated person you must freeze them, must not make anything available to them, and must report to OFSI. Which of those applies turns on the facts, so a match here is the point at which to take advice, not to act unilaterally.

Follow the ownership