Possible sanctions match

A possible match means one thing, precisely: a name on the EU consolidated sanctions list 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

1. 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.
2. Look the entry up on the official list. The EU consolidated list is published by the European Commission and is the authoritative source; the entry will include the identifying details this check lacks.
3. Compare the details you hold — registration number, address, directors — against that entry.
4. 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.
5. 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 list this checks against

The EU consolidated list of persons, groups and entities subject to financial sanctions, refreshed daily and screened locally. The date of the copy used is shown on the result.

Only the version published in the Official Journal of the European Union is authoritative. This is a first-pass screen against a copy of it, and nothing more.