# Possible sanctions match

> A possible match is a name-similarity result against the EU, UK and US sanctions lists, not a legal determination. What it means and how to resolve it.

Canonical: https://vetthisvendor.com/guide/sanctions-possible-match
Published: 2026-08-02. Updated: 2026-08-02.
Author: Jose Pollman, VetThisVendor.

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

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, 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.
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 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.