Denied-party screening

The rules that bind you depend on who you are, what you're shipping and how it's being paid for. US export rules can follow US-origin items outside the US. A US dollar payment can bring in OFAC. And your own government's list applies to you wherever you are. So a UK company selling US-origin parts to a Middle East buyer, invoiced in dollars, could need to look at UK, US and possibly EU lists.

The US Consolidated Screening List has a source column that tells you which list a hit comes from. Don't stop at the hit: each list carries a different legal result.

Note the UK change. The OFSI Consolidated List closed on 28 January 2026, and the UK Sanctions List is the only source now. If your tool still reads the old OFSI feed, it has been out of date since that day.

OFAC. Under the 50 Percent Rule, a company owned 50% or more by blocked persons, alone or together, is itself blocked, even when it's not named.

BIS. The Affiliates Rule, published on 30 September 2025, applied a similar 50% test to the Entity List and other listed end users. It was suspended on 10 November 2025 for a year. A BIS rule filed for public inspection on 5 November 2026 and scheduled for publication on 9 November 2026 keeps the Affiliates Rule stayed until 10 January 2027. So as of 5 November 2026 there's no ownership-based Entity List test in force, but it could return in weeks. Keep your ownership data ready.

UK and EU. Their rules also look at ownership and control, so a name search alone doesn't settle it.

Screening names isn't the same as due diligence. If the buyer is a new trading company with a free-mail address, a freight forwarder as the delivery address, and it wants goods with no obvious use for its business, then a clean name search doesn't settle that.

• Parties: your customer, the ultimate consignee, any end user, freight forwarders, banks, agents, and vessels.
• Moments: when you onboard the party, before each order or shipment, and when lists update for your existing customer base.
• Details: full legal name, trading names, address and country. A list entry may be a person, a company, a vessel or an aircraft.

OFAC doesn't prescribe a specific method. The right depth depends on your risk, and that's your responsibility to set and defend.

Fuzzy matches are common. Here's how you'd work through a hit on an invented customer, "Al Noor Trading LLC", Dubai, for a shipment of pumps:

That's looking like a false positive. But the name and country are close, so get one more piece of evidence, such as the trade licence, and have someone other than the salesperson sign it off. Record what you checked and when. If you can't resolve it, hold the shipment and ask a specialist. A rejected shipment is cheaper than a violation.

If it's a true match, stop. Don't ship, don't refund or return funds on your own initiative, as there may be blocking or reporting duties, and take legal advice straight away.

OFAC raised its recordkeeping requirement from 5 to 10 years, with effect from March 2025, matching the extended limitation period for enforcement. Keep the search date, list version, result, and reasoning. Export-control and customs retention periods differ, so use the longest that applies.

For the goods side, see restricted and prohibited goods. This isn't legal advice, and sanctions questions on a live deal need a lawyer.