Who and what can appear on a sanctions list?
Start by identifying what kind of target you are looking at.
Before deciding what a search result means for a transaction, check the target type and list name. Did you find a person, a company, or a vessel with a similar name? Is the record on the SDN List or another list?
The lists cover more than people and companies
Companies and groups can both appear as entities. For individuals, birth dates, nationality, and ID numbers can help distinguish records. For entities, use registration details and addresses. Vessels and aircraft have identifiers such as IMO numbers or registration marks when the entry provides them.[02]
Four parts of an entry to read first
Entries differ in how much identifying information they contain. A missing field does not rule out a match, and several companies may share an address.[02]
Start with the SDN / non-SDN distinction
SDN List
Generally means blocking property and interests in property, with broad dealing restrictions. Jurisdiction, exemptions, and licenses still matter.
Non-SDN lists
A collection of different lists. Restrictions can concern financing, specified accounts, securities, or other activities; the rules differ.
A company can appear on more than one list. A non-SDN record does not rule out a separate SDN listing. The next chapter compares the main kinds of restrictions.[02][13]
Why is “no result” not enough?
- 01
Names may be missed
Legal names, aliases, transliterations, and spelling variants can affect a search.
- 02
The search may not include every list
Check which lists were searched and whether the information is current.
- 03
Not every restriction needs a separate listing
Examples include the 50 Percent Rule and restrictions involving jurisdictions, governments, or activities.
A name search only tells you part of the story. A company’s owners and the transaction you are considering can also matter.[13]