Sanctions screening
Before completing any international trade transaction, importers and exporters are legally required to verify that their counterparties, destinations, and goods are not subject to government sanctions. Sanctions violations can result in severe civil and criminal penalties regardless of intent.
This page provides a high-level overview for general awareness only. Sanctions regimes are complex, change frequently, and carry serious legal consequences. Commercial importers and exporters should use professional compliance screening tools and seek legal advice specific to their transactions.
What sanctions screening is
Sanctions screening is the process of checking whether a trade transaction — including the parties involved, the destination country, the end use, and the goods themselves — is subject to government restrictions. Sanctions can prohibit transactions entirely, or restrict them unless a licence is obtained.
Sanctions are imposed by governments and international bodies for foreign policy and national security reasons. They operate in parallel with customs law: a shipment can clear customs duty-free under a trade agreement and still be a sanctions violation if the buyer is a designated entity.
Major sanctions programs
US OFAC — Office of Foreign Assets Control
Administers the most extensive sanctions program globally. Publishes the Specially Designated Nationals (SDN) list of blocked persons and entities, as well as country-based comprehensive sanctions programs. US jurisdiction extends to any transaction involving US persons, US dollars, or US-origin goods anywhere in the world.
UK OFSI — Office of Financial Sanctions Implementation
HM Treasury body responsible for implementing UK financial sanctions. Since Brexit, the UK maintains its own consolidated list of designated persons, which overlaps with but is not identical to the EU and US lists.
EU Restrictive Measures
The European Union adopts sanctions through Council Regulations that are directly binding on all EU member states. The EU Sanctions Map provides a searchable interface to all active EU measures. EU sanctions apply to EU persons and entities, and to activities within EU territory.
UN Security Council Sanctions
The UN Security Council can impose sanctions binding on all UN member states under Chapter VII of the UN Charter. These form the baseline layer of international sanctions, which national programs often build upon with additional measures.
Countries with comprehensive sanctions
Some countries are subject to comprehensive sanctions programs that prohibit nearly all commercial transactions. The scope and applicable jurisdictions vary — a transaction prohibited for a US company may be permitted for an EU company, and vice versa.
| Country | US (OFAC) | EU | UK (OFSI) | Notes |
|---|---|---|---|---|
| North Korea | Comprehensive | Comprehensive | Comprehensive | Near-total prohibition; UN arms embargo |
| Iran | Comprehensive | Sectoral | Sectoral | US comprehensive; EU/UK target specific sectors and persons |
| Syria | Comprehensive | Sectoral | Sectoral | US comprehensive; EU/UK target regime-linked individuals |
| Cuba | Comprehensive | Limited | Limited | US embargo ongoing; EU/UK have no broad program |
| Russia | Sectoral | Sectoral | Sectoral | Extensive sectoral sanctions post-2022; not a full embargo |
| Belarus | Sectoral | Sectoral | Sectoral | Broad sectoral measures; significant entity-level designations |
| Myanmar | Sectoral | Sectoral | Sectoral | Military-linked entities designated; not a full trade embargo |
What to screen
Effective sanctions screening covers four dimensions of a transaction:
Legal name and any known aliases of the buyer, seller, freight forwarder, financial intermediary, and beneficial owners. Transliteration variants matter for names in non-Latin scripts.
Country of destination, any transit countries, and the end-user location. Shipping to an unsanctioned country can still be a violation if goods are re-exported to a sanctioned destination.
What the goods will be used for and by whom. Military, nuclear, or surveillance end-uses can trigger controls even for goods not listed on export control schedules.
Dual-use items (goods with both civilian and military applications) are subject to export licensing requirements in addition to sanctions. The EU Dual-Use Regulation and US EAR cover thousands of product categories.
Free screening tools
Official US Treasury search tool for the SDN list and consolidated sanctions lists. Free, real-time, searchable by name or address.
Downloadable CSV and XML files of all UK-designated persons. Updated daily. Can be searched online or downloaded for local screening.
European Commission tool providing an overview of all EU sanctions regimes by country, with links to the Official Journal regulations and designated persons lists.
UN Security Council Consolidated List
Official UN list of individuals and entities subject to Security Council sanctions measures. A baseline that all national programs build upon.
Free tools are adequate for occasional checks. Businesses with regular cross-border transactions typically use commercial screening platforms (e.g., Dow Jones, LexisNexis, Refinitiv, Comply Advantage) that provide automated screening, fuzzy-name matching, and audit trails.
Penalties for violations
United States (OFAC)
Civil penalties up to USD 1,000,000 per violation or twice the value of the transaction, whichever is greater. Criminal penalties up to USD 1,000,000 and 20 years imprisonment. OFAC applies strict liability — no intent to violate is required for civil penalties.
United Kingdom (OFSI)
Civil penalties up to GBP 1,000,000 or 50% of the value of the funds involved, whichever is greater. Criminal penalties of up to 7 years imprisonment and unlimited fines. Since 2022, OFSI can impose penalties on a strict civil liability basis.
European Union
Penalties are set at member-state level and vary significantly by country. Most EU member states impose criminal penalties for serious violations. The EU is working towards harmonised minimum penalties through a Directive on criminal sanctions for breaching EU restrictive measures.
Sanctions regimes change rapidly, particularly in response to geopolitical events. The information on this page reflects the general structure of major programs and is not a substitute for real-time screening against official lists or professional compliance advice.