Sanctions and politically exposed person screening are common elements of customer, vendor, investor and intermediary due diligence. They can help identify whether a party is listed, connected to a listed party or associated with a public function that may require enhanced review.
The search should be treated as part of a wider risk process. A name match is not always a confirmed identity, and a no-match result does not remove every legal or reputational risk.
Define the Parties to Be Screened
The scope may include the contracting entity, trading names, directors, shareholders, beneficial owners, authorized representatives and relevant banks or intermediaries.
Use Relevant Sanctions Sources
The applicable lists depend on jurisdiction, transaction, currency, parties and organizational obligations. Screening may include United Nations, European Union, OFAC and relevant national sources.
Review Ownership and Control
An entity may not appear by name while ownership or control by a listed party creates additional risk under an applicable regime. Ownership analysis should therefore accompany name screening where relevant.
Understand PEP Status
A PEP is a person entrusted with a prominent public function. PEP status is not proof of corruption. It can require additional understanding of the person, role, source of funds, relationship and approval level.
Resolve Possible Matches
Fuzzy and partial matching can return unrelated results. Compare strong identifiers before treating a result as relevant.
- Full name and aliases
- Date and place of birth
- Nationality
- Address
- Company number
- Role and associated entities
Assess the Relationship Risk
The significance of a sanctions or PEP result depends on the law, relationship, geography, ownership and proposed activity. Legal or specialist advice may be required for difficult cases.
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Document the Decision
Record the sources searched, date, identifiers, result classification, escalation and decision. Avoid describing a possible match as confirmed.
Monitor for Change
Sanctions lists, public functions and ownership can change. Long-term or higher-risk relationships may require periodic or event-driven rescreening.
- Ownership change
- New director or representative
- Change in country or payment route
- New adverse information
- List update
- Contract expansion
Global Screenings supports Global Database Searches and due diligence research across relevant sanctions, PEP and public sources.
Contact Global Screenings to discuss sanctions or PEP screening.
