How to check if a company is sanctioned, step by step

Step 1: collect the right names

Before searching, gather the data that makes a search reliable:

• the full legal name and any trading names;
• former names, which you can often find in the company register;
• the country of incorporation and the registration number;
• the names of the main shareholders and of the directors;
• the address, useful to tell apart two companies with similar names.

A search on the trading name alone is the most common mistake. Listed parties often appear under their legal name, under transliterations from other alphabets or under aliases recorded by the authority.

Step 2: search the United States lists

The US Department of the Treasury, through its Office of Foreign Assets Control, publishes the Sanctions List Search tool. It covers the Specially Designated Nationals list and the other Treasury sanctions lists. You can set a minimum match score: a lower score finds more spelling variants but also more names that are only similar.

For export controls, the Department of Commerce publishes the Consolidated Screening List, which brings together lists from the Departments of Commerce, State and the Treasury, including the Entity List. It is useful when you sell goods or technology, not only when you move money.

Step 3: search the European Union and United Kingdom lists

The EU Sanctions Map shows the EU restrictive measures by country and lets you search the people and entities listed. The legal reference is always the regulation published in the Official Journal on EUR-Lex, which the map links for each regime.

In the United Kingdom, the UK Sanctions List published by the Foreign, Commonwealth and Development Office lists the people and entities designated under UK sanctions regulations. The Office of Financial Sanctions Implementation, part of HM Treasury, publishes guidance on financial sanctions.

If you work in other countries, check whether they publish their own lists: Switzerland, Canada, Australia and Japan, among others, have autonomous sanctions.

Step 4: look beyond the name

A clean result for the company name is not the end of the check. In the United States, companies owned 50% or more, directly or indirectly, by one or more blocked persons are blocked themselves, even if they appear on no list. The European Union and the United Kingdom look at ownership and control. That is why you also search the main owners and directors.

When the ownership chain passes through several companies or countries, a simple search is not enough to see who is really behind the counterparty. In that case a full company report, with the beneficial owners, is the next step.

Step 5: read a possible match carefully

Search tools show possible matches, not verdicts. Compare the details of the listed entry with what you know about the company: country, address, registration number, date of incorporation, names of the owners. If the identifying data differ clearly, the match is probably a namesake. If they agree, or you cannot tell, stop the transaction and ask your compliance or legal advisers before going ahead.

Step 6: record what you did

Keep a short record for every check: date and time, tool used, names searched, settings such as the match score, result and decision, with the name of the person who decided. A screenshot or an export of the results helps. In the United States, records of transactions subject to sanctions rules must be kept for 10 years. A clear record is what shows, later, that you had a process and followed it.

Checklist for every new counterparty

1. Collect legal name, former names, country, registration number, owners and directors.
2. Search the US Treasury Sanctions List Search and the Consolidated Screening List.
3. Search the EU Sanctions Map and the UK Sanctions List.
4. Repeat the searches for the main owners and directors.
5. Compare identifying data for every possible match.
6. Save the record and repeat the check regularly, because lists change.

The limits of manual checks

Manual searches work well for a few new counterparties. They become hard to sustain when you need to repeat them for hundreds of existing customers and suppliers, because each list is updated on its own schedule and every repetition has to be recorded again. That is the point where most companies move to an automatic check.

Where Unicorn Intelligence fits

Unicorn Intelligence runs these checks on every company in your CRM every day and records each decision; new accounts receive a $50 credit.

Frequently asked questions

Is there a free way to check if a company is sanctioned?

Yes. The US Treasury Sanctions List Search, the US Consolidated Screening List, the EU Sanctions Map and the UK Sanctions List are free official tools.

Is searching the company name enough?

No. Search former names and the main owners and directors too, because a company owned or controlled by listed persons can be restricted without being listed itself.

What should I do if the tool shows a possible match?

Compare country, address, registration number and owners with the listed entry. If they agree or you cannot tell, stop the transaction and ask your compliance or legal advisers.

Do I need to keep a record of the check?

Yes. Record date, tool, names searched, result and decision. In the United States, records of transactions subject to sanctions rules must be kept for 10 years.