Updated

GL-S-03

Glossary · Due Diligence and compliance

Sanctions screening - the check where a name match stops an application

Sanctions list screening — matching a person or company against international sanctions databases during compliance and Due Diligence.

Full glossary
screeningagainst databases
stopin the event of a match
in advancebetter to check

01 / In 30 seconds

The short answer

What it is
Sanctions screening — checking a person or company against sanctions lists
When
In due diligence, opening accounts, applying for citizenship
What is searched for
Matches in sanctions databases (OFAC, EU, UN and others)
Bottom line
Sanctions are almost always a deal-breaker
How to use it
Check yourself in advance and clear false matches

02 / In plain words

What Sanctions Screening means

Sanctions screening is a mandatory stage of compliance at which a person or company is checked against international sanctions databases. Banks, citizenship programmes and payment systems check whether the client (or persons connected with them) is under sanctions of the United States (OFAC), the European Union, the UN, the United Kingdom and other jurisdictions.

The check runs through special databases and systems: the client’s name is compared with lists of sanctioned persons and organisations. If a match is found, it is almost always a deal-breaker: a bank will not open an account, and a state will not issue a passport to a sanctioned person. There are also “false positives” — name matches with another person, which need to be cleared properly by proving that it is not you.

Sanctions screening is an integral part of due diligence and should be approached seriously. Concealing sanctions status is impossible: the check will find it. But a false match can also hold up the process if it is not explained. That is why it makes sense to check yourself in advance against the same databases compliance uses and prepare explanations. We carry out such a preliminary check and help clear false matches.

A case from practice

During a check, a client’s name matched a sanctioned person — a namesake from another country. Without an explanation this would have frozen the process. We identify such a match in advance and prepare documents proving that it is a different person — and the screening goes through without delays.

Where screening is used

  • Due diligence for citizenship and residence
  • Opening bank accounts
  • Checking clients and partners
  • International payments
  • Clearing false name matches
  • A preliminary self-check

03 / What it covers

What matters about sanctions screening

01

What it is

  • Checking against databases
  • Part of compliance
  • In due diligence
02

Lists

  • OFAC (USA)
  • EU and UN
  • The United Kingdom and others
03

Bottom line

  • Sanctions are a deal-breaker
  • Refusal of an account
  • Refusal of a passport
04

Nuance

  • False matches
  • By name
  • Must be cleared properly

04 / How it works

How screening works

Step 1

A preliminary self-check

We check you against sanctions databases before submission.

Step 2

Checking against sanctions databases

Compliance matches the name, date of birth and connections.

Step 3

Reviewing matches

We review every match found.

Step 4

Clearing false positives

Documents showing it is a different person.

Step 5

A clean result

The check is passed without delay.

05 / Key facts

What you need to know

01What it is

Matching against lists

A person or company is checked against sanctions databases.

02Which lists

OFAC, EU, UN, UK

And lists of other jurisdictions, including for related persons.

03A match

Almost always a stop

A bank will not open an account, and a state will not issue a passport to a sanctioned person.

04False positive

Cleared with documents

A name match with another person is cleared by proving it is not you.

Common mistakes

Not checking yourself in advance

Run a self-check against the same databases as compliance.

Not preparing explanations for a name match

Gather documents that distinguish you from the namesake.

Hiding sanctions status

Account for it in the plan: the check will find it.

06 / Expert advice

Klara Rihter

How to prepare in advance

Before applying for citizenship or opening an account, it makes sense to check yourself against the same sanctions databases compliance uses and identify possible matches in advance. If it is a false positive on a name, documents are prepared proving that it is not you. Then sanctions screening does not hold up the process but goes through cleanly and predictably.

What we do for you. We check you in advance against the same sanctions databases compliance uses, so that there are no surprises. If a false name match arises, we prepare documents proving that it is not you and clear it properly. That way sanctions screening goes through cleanly and the process is not held up.

Klara RihterBanking compliance and source of funds specialist

07 / Questions

Frequently asked questions

Checking a person or company against international sanctions databases (OFAC, EU, UN and others) in compliance, due diligence and when opening accounts.

It is almost always a deal-breaker: a bank will not open an account, and a state will not issue a passport to a sanctioned person. Sanctions status is a serious obstacle.

A name match with another person on a sanctions list. It must be cleared properly by proving with documents that it is not you, otherwise the process will be held up.

No. The check will find it in the databases. Concealing it is pointless and dangerous; sanctions issues are dealt with openly.

The sanctions lists of the United States (OFAC), the European Union, the UN, the United Kingdom and other jurisdictions, as well as connected persons and organisations.

Check yourself against the same databases compliance uses and prepare explanations in case of a false match. We carry out such a preliminary check.

Author: Klara Rihter

Reviewed by: Dmitry Nagy

Sources: OFAC — on sanctions programmes

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