Updated

GL-S-03

Glossary · Due Diligence and compliance

Sanctions lists - lists where a match almost always means refusal

Sanctions lists — registers of persons and companies with whom transactions are restricted or prohibited; maintained by OFAC, the EU, the UN, the UK and others.

Full glossary
manydifferent lists
banon transactions
stopin the event of a match

01 / In 30 seconds

The short answer

What it is
Sanctions lists — lists of persons and companies under restrictions
Who administers it
OFAC (USA), the EU, the UN, the United Kingdom and others
What it means
Transactions with listed persons are restricted or prohibited
During checks
A match is almost always a deal-breaker
How to use it
Check in advance that you are not on the lists

02 / In plain words

What Sanctions lists means

Sanctions lists are official lists of individuals, companies and organisations against which states and international bodies have imposed restrictive measures. Being included on such a list means that doing business with the person is prohibited or severely restricted: assets are frozen, transactions blocked, and access to the financial system of the jurisdiction concerned closed.

There are many lists, kept by different bodies: OFAC in the US (including the well-known SDN List), the European Union, the UN, the United Kingdom (OFSI) and individual countries. The lists differ in scope and grounds and are updated regularly, and because of the global role of the dollar and major financial centres many of them have a cross-border effect — banks around the world check against them so as not to breach sanctions.

In investment migration and bank compliance, checking against sanctions lists is mandatory: a match almost always becomes a deal-breaker for opening an account or obtaining citizenship. False name matches are possible, however, and need to be cleared properly. We check clients against the key lists in advance and help resolve any questions before filing.

A case from practice

A client is clear on the OFAC list, but a match comes up on the EU list — for a namesake. Checking only one list, it would have been easy to miss this. We check against several key lists at once and clear the false match in advance, so that it does not surface at the bank at the worst possible moment.

Where the lists are used

  • Sanctions screening in due diligence
  • Opening bank accounts
  • International payments and business
  • Checking clients and partners
  • Sanctions risk assessment
  • Clearing false name matches

03 / What it covers

What matters about sanctions lists

01

Who administers it

  • OFAC (USA)
  • EU and UN
  • The United Kingdom and others
02

What they mean

  • Frozen assets
  • Blocked transactions
  • A ban on doing business
03

Effect

  • Cross-border influence
  • Banks check against them
  • Deal-breaker
04

Keep in mind

  • Updated regularly
  • Different scope
  • False matches are possible

04 / How it works

How checks against the lists work

Step 1

A preliminary check

We check you against the lists before you apply.

Step 2

Checking against the key lists

OFAC, the EU, the UN, the UK and others.

Step 3

Reviewing matches

Date of birth, nationality, documents - is it you or not.

Step 4

Clearing false positives

We prepare evidence that the match is false.

Step 5

A clean result

The bank and the programme see a clean result.

05 / Key facts

What you need to know

01What they are

People and companies under restrictions

Doing business with listed parties is banned or restricted: assets are frozen, transactions blocked.

02Who keeps them

OFAC, the EU, the UN, the UK

The US has the SDN list, the UK has OFSI, and the EU, the UN and individual countries keep their own.

03Reach

A cross-border effect

Because of the dollar and major financial centres, banks worldwide check against other countries' lists.

04A match

A stop factor or a namesake

A real match blocks an account or citizenship. A false name match is cleared with documents.

Common mistakes

Checking only one list

Check OFAC, the EU, the UN and the UK at the same time.

Not checking yourself in advance

Run the check before applying and see any matches first.

Trying to hide sanctions status

Deal with it by challenging the listing, not by hiding it.

06 / Expert advice

Klara Rihter

How to prepare in advance

Before applying for citizenship or opening an account, check against the key sanctions lists (OFAC, the EU, the UN, the UK), not just one. If a false name match arises, documents are prepared proving that it is not you. The lists are updated, so current data are relied on. Then the sanctions check goes through cleanly and predictably.

What we do for you. We check clients against the key sanctions lists at once — OFAC, the EU, the UN, the UK — not just one, and take their cross-border effect into account. In the event of false name matches, we prepare documents that settle the question. That way the sanctions check goes through cleanly, with no surprises on the bank’s side.

Klara RihterBanking compliance and source of funds specialist

07 / Questions

Frequently asked questions

Official lists of persons, companies and organisations under restrictive measures. Inclusion blocks their assets and transactions in the jurisdiction concerned.

Different bodies: OFAC in the US (including the SDN List), the European Union, the UN, the United Kingdom (OFSI) and individual countries. The lists differ in scope and grounds.

Many have a cross-border effect: because of the role of the dollar and major financial centres, banks around the world check against them so as not to breach sanctions.

It is almost always a deal-breaker: a bank will not open an account, and a programme will not issue a passport. Sanctions status is a serious obstacle in finance and immigration.

Yes, on names, with a namesake on a list. They must be cleared properly with documents proving that it is not you — otherwise the process will be held up.

By checking against the key lists before applying. We carry out such a preliminary check and, in the event of a false match, prepare explanatory documents.

Author: Klara Rihter

Reviewed by: Dmitry Nagy

Sources: OFAC — on sanctions lists

INITIAL ASSESSMENT

Tell us what outcome your family needs

We will design a solution for your case, choose the country and the right status, and take the whole process through to the result.

Or message us on WhatsApp or Telegram

Anna Kovalevskaya, lead lawyer at BRIDGES GLOBAL
Anna KovalevskayaLead lawyer, citizenship and residency, 12 years of practice