Sanctions and watchlist screening

The lists that matter

No single list is complete. A counterparty file screens the parties, their directors and their known owners against at least the following, each cited with the retrieval date and list version.

Many organisations add politically exposed person data and adverse-media feeds. These are not sanctions and are labelled differently in the dossier.

False positives and how to clear them

Most hits are not matches. Lists carry many aliases and transliterations, and common names in Chinese, Arabic, Russian and Spanish will produce fuzzy hits on almost any screening run. A hit is cleared or confirmed on secondary identifiers, never on the name alone.

• For persons: date of birth, nationality, passport or national ID number, known addresses, and the programme under which they were listed.
• For entities: registration number, address, country, known officers, and the listing narrative.
• For vessels: IMO number and flag.

OpenDossier records each hit with the list, the matching score, the fields compared and the reason for clearance, so a reviewer can see that a hit on Wang Wei was dismissed because the listed person's date of birth and nationality do not match the director in the registry extract. Cleared hits are kept, not deleted; the record of having considered them is part of the evidence that screening was done properly. A hit that cannot be cleared on available data is reported as an open question, not as a match.

Ownership and control: the 50% rule and its cousins

A company need not be named on a list to be subject to sanctions. OFAC's guidance (FAQ 401) states that an entity owned 50% or more, directly or indirectly, in aggregate by one or more blocked persons is itself blocked, whether or not it is listed. The EU and UK apply similar concepts: in the EU, ownership of more than 50% or control; in the UK, ownership of more than 50% of shares or voting rights, or the right to appoint or remove a majority of the board, or other control, as set out in OFSI guidance. Thresholds and the treatment of aggregation differ by regime, so the dossier names the regime for each conclusion.

This is why ownership evidence feeds sanctions screening. A clean name screen on the counterparty means little if its 60% shareholder is a listed person. The chain for an ownership-based conclusion therefore cites the ownership record (register, PSC entry, company-supplied shareholder list) alongside the list entry.

Where ownership is not public and the company has not supplied it, the dossier states that ownership-based screening could not be completed. That statement is itself a finding a reader needs.

Screening cadence

Lists change frequently, sometimes daily during active programmes. A reasonable cadence, which should be matched to your own policy and regulator expectations, looks like this:

• At onboarding, before any contract or payment.
• On every material list update for counterparties in higher-risk sectors or geographies; many organisations run daily delta screening.
• Before significant payments, especially cross-border.
• On any change of director, owner or registered address identified by monitoring.
• At a fixed interval (quarterly or annually) for all active counterparties, as a backstop.

Each run is recorded with the list versions used. In a dossier this appears as a dated claim such as No matches on OFAC SDN, UN, EU, UK, MAS, DFAT and Canadian lists; lists as published on 20 October 2026; two false positives cleared. The retrieval date is what makes the claim meaningful; a screen from last year proves nothing about today.

What screening does not cover

Sanctions lists are a narrow instrument. They do not cover export-control restrictions on goods and technology (which depend on the item and end use as much as on the party), sector-wide restrictions that apply to unlisted entities in named industries or regions, secondary sanctions exposure, or domestic legal prohibitions on dealing with certain persons. They also lag events: a person may be charged, named in the press or subject to an asset freeze in one country before any list is updated.

A dossier therefore pairs list screening with the ownership section, the litigation and regulatory section and the monitoring feed. Where a counterparty operates in a sector or region subject to programme-level restrictions, the dossier notes the programme and leaves the legal assessment to the reader and their advisers.

Nothing in this guide is advice on whether a transaction is permitted; it describes how evidence is gathered so that your compliance function can decide.