Possible sanctions match
By Jose PollmanPublished
A possible match means one thing, precisely: a name on one of the sanctions lists this tool screens against closely resembles the name that was checked.
It is not a finding that your supplier is sanctioned. It is a prompt to look properly.
Why the result is deliberately vague
Sanctions lists identify people and organisations by name, and names are a poor identifier. The list carries every member state’s transliteration of the same entity, so one organisation may appear a dozen times in different spellings. Meanwhile, ordinary companies share names with sanctioned ones by pure coincidence, and common surnames appear on the list in large numbers.
Matching on name similarity alone therefore produces both kinds of error. This tool is tuned to prefer missing a borderline spelling over flagging an innocent supplier, because a false accusation is the one that gets acted on.
What this check does not use
A real sanctions determination turns on identifiers this tool never sees:
- date and place of birth, for individuals
- registration number and registered address, for companies
- ownership and control — an unlisted company can still be caught if a sanctioned party owns more than 50% of it, which no name check can detect
So a “no match” result is also limited. It means no similar name was found, not that the entity is clear.
What to do with a possible match
- Read the matched name and its score. A 100% match on an exact, distinctive company name is very different from an 86% match on a common surname.
- Look the entry up on the official list, and note which one. The result names the programme a match came from, which tells you where to look: the EU list is published by the European Commission, the UK list by OFSI, and the US SDN list by OFAC. Each is the authoritative source for its own designations and none of them speaks for the others. The official entry will include the identifying details this check lacks.
- Compare the details you hold — registration number, address, directors — against that entry.
- Escalate rather than decide alone. If the details are consistent, this stops being a bookkeeping question. Your compliance contact or a lawyer should handle it, and payment should not proceed in the meantime.
- Do not tell the supplier they are “on a sanctions list” on the strength of a name check. If it is a coincidence, you have accused a customer’s counterparty of a serious offence.
The lists this checks against
Three, refreshed daily and screened locally. The date of the copy used is shown on the result.
- The EU consolidated list of persons, groups and entities subject to financial sanctions. Authoritative only as published in the Official Journal of the European Union.
- The UK sanctions list, published by the Office of Financial Sanctions Implementation (OFSI).
- The US Specially Designated Nationals (SDN) list, published by the Office of Foreign Assets Control (OFAC).
The UK and US lists are included because their reach does not stop at their borders. OFAC designations in particular affect anyone transacting in US dollars or through US banks, which covers a great many European businesses that have never thought about it.
Ships and aircraft are excluded from all three. A vessel named Fortune raising a match against a supplier called Fortune Ltd is noise, and this tool screens the name on an invoice.
Being on one list and not another is normal and meaningful — the three authorities designate independently. This remains a first-pass screen against copies, and nothing more.
Run a vendor check →Registry, IBAN, EU sanctions and sending domain, in one pass. Free, no signup.
Invoice Checker →Drop in a supplier’s invoice, or paste its text, and the VAT numbers, bank accounts and email domains on it are read out in your browser — the file itself is never uploaded. Correct anything misread, then run every check at once.