What Is Sanctions Screening?

A new customer from abroad, a supplier in a third country, an unusual payment: in situations like these, a simple question arises. Is one of the persons or companies involved affected by sanctions? Sanctions screening, also called a sanctions check, is the usual way of answering this systematically before a transaction is concluded or continued.

This article is the starting point for anyone who wants to screen business partners. It explains what is checked, which lists play a role for Swiss companies, how possible hits are to be assessed, what is required by law and what is practice, and where a sanctions check reaches its limits, for example in export transactions. In-depth articles on individual lists are linked throughout.

In brief: What is sanctions screening?

Sanctions screening compares the names and other identifying details of individuals, companies or organisations with sanctions lists, for example the lists of SECO, the EU or the UN. A hit is initially only a pointer for review: it shows a possible match but does not confirm that the same person is meant. Whether a hit is correct, which requirements apply and how the transaction proceeds must be assessed by a qualified person and documented.

Note: This article is for general information and is not legal advice. Publisher: Daniba Services GmbH, operator of sanctioncheck.ch (legal notice, in German). Status of the legal review: 12 October 2026. The sources are listed at the end. Where something is required by law, the reference is given; everything else is marked as practice or classification.

Key points

• Sanctions screening is more than a name search: it compares names, alias names and other details and assesses possible hits.
• A name match is not yet a confirmed hit.
• For Swiss companies, Swiss law is the starting point: the Embargo Act and the ordinances of the Federal Council, enforced by SECO. According to SECO, sanctions of third countries have in principle no direct effect in Switzerland, and EU sanctions do not apply automatically.
• How relevant a list is depends on the transaction and its connection. Foreign lists can be relevant in practice, for example because of banks, payment routes or contracts.
• The sources reviewed for this article contain no general rule on which lists must be checked and in what form. According to SECO, responsibility for complying with sanctions lies with companies.
• Sanctions screening is not export control screening: the goods, the country of destination, the end use and embargoes are separate questions.
• Documented screening creates traceability. Software supports the process but does not replace a qualified assessment.

Why do sanctions lists exist?

Sanctions are coercive measures by which states or groups of states react to certain conduct. In Switzerland the Embargo Act is the legal basis. It empowers the Federal Council to adopt such measures, which according to the information provided by SECO (in German) include financial sanctions, trade restrictions, travel bans or the freezing of assets. SECO is responsible for enforcement and supervision.

So that it is clear whom a measure affects, persons, companies and organisations are named. The United Nations maintains a “Consolidated List” containing all individuals and entities against which the Security Council has imposed measures. The European Commission maintains a consolidated list of the persons, groups and organisations subject to EU financial sanctions. An entry does not automatically mean that someone has been convicted of a criminal offence.

What does a listing mean for companies?

What a listing actually brings about is regulated by the relevant sanctions regime. By way of example, the Ukraine Ordinance of the Federal Council (SR 946.231.176.72, version of 1 September 2026, in German) provides that funds and economic resources owned or controlled by the listed persons, companies and organisations are frozen. It is prohibited to transfer funds to them or to make funds and economic resources available to them directly or indirectly. Anyone who holds or manages funds that must be assumed to fall under the freeze must report this to SECO without delay. Violations are punished under the Embargo Act and prosecuted by SECO (Art. 15, 16 and 32 of the Ordinance).

These rules apply to the regime mentioned. Other sanctions regimes may differ. For a specific case, the relevant ordinance is therefore decisive.

Ownership and control

According to SECO, in the case of an asset freeze civil-law ownership in principle remains with the person concerned. What is frozen is use: the Ukraine Ordinance understands the freezing of funds as preventing any action that would allow the management or use of the funds (Art. 1). It expressly also covers companies that are owned or controlled by listed persons (Art. 15 para. 1 let. c). The legal position differs from state to state: under its FAQ 398, the US authority OFAC applies a “50 percent rule” that looks only at ownership, not at control. For the EU and the United Kingdom, this question was not examined for this article. In practice this means that anyone who screens only the direct contracting party may not see everything that can be relevant for the transaction.

What is checked in sanctions screening?

Anyone who wants to screen companies or persons against sanctions lists needs details about the parties to a transaction. Depending on the case, these include:

• Individuals: full name, date of birth, nationality, address.
• Companies and organisations: company name, former and alternative names, registered office, registration details.
• Alias names and spelling variants: names are often listed in several spellings, including in other scripts.
• Other identifying details: for example identity document details, where known.
• Beneficial owners or controlling persons: where this is necessary in the specific case.

A blanket statement that all governing bodies, employees or investors must always be screened cannot be derived from the sources reviewed. How wide the circle is drawn is a risk-based decision of the company. For financial intermediaries subject to the Anti-Money Laundering Act (AMLA), establishing the beneficial owner is a due diligence obligation of its own (Art. 4 AMLA). The 25 percent threshold mentioned in the AMLA (Art. 2a para. 3 AMLA) is a definition in the Anti-Money Laundering Act and not a general threshold of sanctions law.

Which sanctions lists matter for Swiss companies?

The lists are not identical. They come from different bodies and rest on different legal bases, and even within a single list different criteria and measures apply depending on the regime. A person can be on one list without appearing on another.

For Swiss companies, Swiss law is the starting point. According to SECO, sanctions measures of third countries in principle have no direct effect in Switzerland. Foreign lists can nevertheless be relevant in practice because of the connection of the transaction, payment routes, the banks involved, contractual relationships or internal policies. That does not make these sanctions Swiss law. An overview of how to choose lists is provided in the article Which Sanctions Lists Matter for Swiss Companies?

Anyone who wants to check the Swiss sanctions list uses SECO’s search for sanctions addressees (checking the SECO sanctions list). SECO also recommends subscribing to its news service for changes.

Who should screen against sanctions lists?

A general statutory screening obligation for all companies is not established in the sources reviewed. The business model and the risk are decisive. Typically, the following groups deal with the question:

• internationally active companies and exporters;
• trading and logistics companies with cross-border supply chains and payments;
• financial intermediaries;
• trustees and certain advisers;
• real estate companies;
• companies with complex ownership structures or cross-border payments;
• compliance officers, management and legal departments responsible for sanctions compliance in Switzerland.

For financial intermediaries subject to the AMLA, the law provides that they take the organisational measures necessary to prevent money laundering and terrorist financing as well as violations of coercive measures under the Embargo Act (Art. 8 AMLA). Since 1 October 2026, a corresponding rule applies to certain advisers (Art. 8d AMLA). The law does not prescribe in detail what these measures look like. For the position in land transactions see Sanctions Screening in Real Estate Transactions.

For all other companies, according to SECO it is in principle their responsibility to comply with sanctions and to keep informed of changes. Violations can have criminal consequences.

When should screening take place?

When to screen is a risk-based decision. As operational practice, the following points in time are suitable:

• before entering into a relevant business relationship;
• before a risk-relevant transaction;
• when ownership or control changes;
• when new risk indications arise;
• again during longer-running business relationships, where appropriate.

A fixed screening frequency is not established in the sources reviewed; the article therefore names none. For financial intermediaries, the AMLA links the frequency of controls and the updating of records to the risk posed by the contracting party (Art. 6 para. 1 and Art. 7 para. 1bis AMLA). That lists change is a reason not to regard screening as permanently sufficient: the UN list and the list of the United Kingdom each state the date of their last update on their pages.

How does sanctions screening work?

In everyday use you will come across various terms for the same process: sanctions check, sanctions screening, sanctions list screening and, in German, Sanktionsprüfung or Sanktionsscreening. A “global sanctions check” usually refers to the joint comparison of lists from several states or organisations. “Global” does not mean guaranteed full coverage of all legal systems, lists and trade restrictions.

The following procedure is an operational guideline, not a statutory procedural rule:

1. Identify the parties and the purpose of the check: who is involved in the business relationship or transaction, and why is it being screened?
2. Collect identity details: names, spelling variants, dates of birth, registered office and other details.
3. Determine the relevant lists: according to the connection of the transaction and the risk.
4. Compare names and identifying details.
5. Review possible hits: compare details, look at the basis of the listing.
6. Document the decision: result, reasons, responsible person.
7. Escalate internally where necessary and involve specialist advice.

Exact and fuzzy search

An exact search finds entries whose name matches the search term. This is fast but misses variants. Lists often record names in several spellings, in Latin script and in other scripts. Depending on the transliteration, the same person may be spelled differently. Typing errors, swapped parts of a name or titles also change the result.

A fuzzy search also finds similar spellings. This reduces the risk of overlooking an entry. The price is that more hits are shown which, on closer review, turn out to be similar names (false positives). The more widely similarity is defined, the more false alarms are to be expected. Conversely, even a fuzzy search cannot cover every spelling variant. A result without hits is therefore always a statement about the comparison at the time of the check, not about the person as a whole.

What is a possible hit?

A possible hit (also called a possible sanctions list hit) is a match or similarity between the search term and a list entry. It is a pointer for review:

• The name alone is often not enough to identify a person or organisation.
• Further details should be compared: date and place of birth, nationality, address or registered office, registration details, function and the basis of the listing.
• The possible match and the comparison should be documented.
• A hit should neither be cleared nor discarded automatically.
• Where there is doubt, professional and, where necessary, legal clarification is appropriate.

The AMLA does recognise similarity expressly, in a narrow context: financial intermediaries must clarify the background if data of a contracting party or beneficial owner match certain data forwarded to them, or are “very similar” to them (Art. 6 para. 2 let. d AMLA). This concerns the data forwarded under Art. 22a AMLA (lists of other states on terrorist activities) and not sanctions lists in general. It does show, however, that assessing similarity is a task for qualified people.

False positives and similar names

A false positive is a possible hit that proves, on careful review, to be a false alarm. Reasons include common names, different transliterations, incomplete source data or similar company names.

Fictitious example (not a real person): a company screens a business partner named “Alexander Muster”. The screening shows an entry “Aleksandr Muster”. The name is almost the same and could be the same person in a different transliteration. A comparison of the other details, however, shows a different year of birth and a different nationality. This suggests that it is a different person. The company documents the comparison and the reasons why the hit does not apply. If the details were similar or incomplete, further clarification would be needed.

Sanctions screening, KYC, AMLA and PEP: the differences

Several checks are often mixed up in everyday practice. They serve different purposes and do not replace one another. The AMLA references apply to companies that are subject to the AMLA.

A PEP can be on a sanctions list but does not have to be, and vice versa. More on this in the article PEP list vs. sanctions list. SECO also distinguishes the Embargo Act, which regulates sanctions and the obligations of those concerned, from the Anti-Money Laundering Act, which regulates due diligence in financial transactions.

How do you document sanctions screening?

Anyone who wants to document a sanctions check is best advised to distinguish between statutory requirements and practice. First the statutory side: for financial intermediaries subject to the AMLA, Art. 7 AMLA requires the necessary clarifications to be documented in such a way that qualified third parties can form a reliable judgement on compliance with the Act. The records are to be updated, and they are to be kept for at least ten years after the end of the business relationship or the completion of the transaction. This rule concerns records under the AMLA. A general documentation or retention period specifically for sanctions screening that applies to all companies is not established; the article therefore names none.

As practice it is advisable to record the following:

• date and time of the check;
• person or organisation checked;
• identifying data used;
• lists taken into account;
• data status of the lists;
• search result;
• assessment of a possible hit;
• reasons and decision;
• responsible person.

These fields are not statutory in every case. They do, however, make it traceable who decided what, when and on the basis of which data.

Common mistakes

• Taking only one list into account;
• screening only the direct contracting party;
• leaving beneficial owners unchecked although they are relevant for the transaction;
• treating a name match as a confirmed hit;
• discarding a hit solely because of a different spelling;
• not documenting anything;
• presenting foreign lists automatically as Swiss law;
• regarding a one-off check as permanently sufficient regardless of changes;
• equating sanctions screening with export control screening;
• adopting a software result without qualified review.

Manual or automated screening?

Both routes are possible. Which one fits depends on volume, risk and documentation requirements.

An automated comparison relieves the workload but does not replace the assessment and gives no assurance that no entry has been overlooked.

Is sanctions screening sufficient for exporters?

Not automatically. Sanctions screening compares individuals, companies and organisations with the sanctions lists taken into account. It is not a complete export control check. For exporters, depending on the transaction, the product or good, the country of destination, the recipient, the end use, other parties involved, the payment route and other legal connections can also play a role. The following checks must not be equated:

• Sanctions screening: comparison of individuals, companies and organisations with name lists.
• Export control and dual-use check: clarifying whether a good (goods, technology or software) is controlled. In Switzerland the Goods Control Act (GKG) and the Goods Control Ordinance (GKV) are the basis. SECO is the licensing authority for dual-use goods and specific military goods. Goods that can be clearly assigned to an export control number in the annexes of the ordinance require a licence (Art. 3 para. 1 GKV; SECO: legal bases and classification of goods, both in German).
• Embargo check: in addition to lists of persons, sanctions ordinances contain prohibitions on certain goods and territories. The Ukraine Ordinance, for example, regulates export restrictions for iron and steel products or luxury goods (Art. 14 et seq.). Such prohibitions do not result from a name check.
• End-use check: clarifying what a good is used for and by whom. According to SECO, a licence is required for goods that are not listed if the exporter knows or has reason to assume that they are intended for ABC weapons (Art. 3 para. 4 GKV). SECO provides, among other things, a form for the end-user statement.

For the classification of goods, SECO describes a screening cascade that first takes into account prohibitions and licence requirements arising from sanctions measures and the War Material Act and only then carries out the classification under the annexes of the Goods Control Ordinance. Sanctions screening is thus one building block, not the whole.

Foreign export controls can also be relevant in practice, depending on the origin of the goods and the parties involved. The EU regulates the export of dual-use items in Regulation (EU) 2021/821, with licensing decisions taken by the national authorities. US export law (Export Administration Regulations, Part 744) provides for licence requirements for goods subject to that law where certain listed parties are involved. These are foreign rules; whether and how they affect a specific transaction must be clarified in the individual case.

Which additional checks are required depends on the specific transaction and on the legal systems that apply. sanctioncheck.ch supports only the screening of individuals, companies and organisations against the sanctions sources available on the platform. It does not check goods lists or the annexes of the Goods Control Ordinance. sanctioncheck.ch does not replace export classification, licence review, end-use review or legal advice. A screening report without hits says nothing about whether a good requires a licence.

Which sources does sanctioncheck.ch take into account?

A distinction between three levels helps here:

1. Sanctions lists and measures that can be relevant depending on the transaction: these are the lists described in this article. Their relevance depends on the transaction and on the legal system.
2. Sources that sanctioncheck.ch takes into account at the time of a check: sanctioncheck.ch compares individuals, companies and organisations with the sanctions sources available on the platform at the time of the check. The sources currently offered are listed on the home page. The PDF screening report lists the platform’s sources and shows the data status stored at the time of the check; if a source is not listed under “Data status of the sources checked”, no data from that source was available at that time.
3. Additional checks that are not automatically covered: export control, goods, end-use, embargo or trade checks (see above).

The sources may change. Full coverage of all lists, legal systems and trade restrictions worldwide is neither offered nor assured.

How does sanctioncheck.ch help?

On sanctioncheck.ch you can compare individuals, companies and organisations with the sanctions sources available on the platform using a single input field. The results distinguish exact hits, hits via alias names and similar hits. Every check can be recorded as a PDF report. The report contains the search term, date and time, a reference number, the data status of the sources as stored at the time of the check and, for each possible hit, the details available in the list, such as programme, date of birth, nationality and alias names.

A check requires registration with e-mail confirmation; after that, three free checks are available. The prices are publicly available.

The platform supports screening and its documentation. It does not make a final decision on hits, does not guarantee complete coverage and replaces neither a professional nor a legal assessment, nor export control or classification of goods. The absence of a hit does not rule out sanctions or export risks. Responsibility remains with the company.

Screen individuals and companies against the sanctions sources available on sanctioncheck.ch and document the lists considered and the results: start a sanctions check.

Checklist for companies

1. Clarify whether and in what role the company is subject to the AMLA.
2. Decide who in the company is responsible for sanctions matters.
3. Assess the business model for sanctions risks: countries, payment routes, products, ownership structures.
4. Determine which lists are taken into account for which transactions.
5. Decide whom to screen: contracting party, beneficial owners, other parties.
6. Set the points in time for screening and the occasions for repeat screening.
7. Provide a procedure for possible hits: comparison of details, escalation, decision.
8. Document every check in a traceable way, with date, lists taken into account and data status.
9. For export transactions, additionally check the goods, the country of destination, the end use and embargoes.
10. Follow changes to Swiss sanctions, for example through SECO’s news service.
11. Review the procedure regularly and seek legal advice where necessary.

You can try out the comparison and documentation (points 4 to 8) in practice: start a sanctions check. After registration, three free checks are available.

Conclusion

Sanctions screening is more than a name search: it comprises the comparison, the assessment of possible hits and the documentation. Which parties and which lists are relevant depends on the transaction. Swiss law is the starting point; foreign lists can play a role in practice without being Swiss law. For exporters, checking names does not replace checking the goods, the country of destination and the end use. Possible hits must be assessed by qualified people, and traceable documentation creates transparency. Responsibility remains with the company.

Further topics

• Which Sanctions Lists Matter for Swiss Companies?
• SECO sanctions list explained
• UN sanctions list explained
• EU Sanctions List: What Swiss Companies Need to Know
• OFAC sanctions list explained
• UK sanctions list explained
• PEP list vs. sanctions list: the difference
• Sanctions Screening in Real Estate Transactions in Switzerland

Official sources

The information is based on the following sources (status of the source check: 12 October 2026). The Swiss legislation is available in the official languages German, French and Italian; the English terms used here are for information only.

• SECO: General information on sanctions (German)
• SECO: FAQ on Swiss sanctions (German)
• SECO: Sanctions ordinances (German)
• SECO: Search for sanctions addressees (German)
• SECO: Industrial goods, legal bases and forms (German)
• SECO: Classification of industrial goods (German)
• Fedlex: Anti-Money Laundering Act (SR 955.0), version of 1 October 2026 (German)
• Fedlex: Ordinance on measures in connection with the situation in Ukraine (SR 946.231.176.72) (German)
• European Commission: Overview of sanctions and related resources
• Council of the EU: How the EU adopts and reviews sanctions
• European Commission: Exporting dual-use items
• United Nations: Security Council Consolidated List
• OFAC: FAQ 11, Who must comply with OFAC sanctions?
• OFAC: FAQ 398, Entities owned by blocked persons
• US Bureau of Industry and Security: EAR Part 744, Control Policy: End-user and End-use Based
• UK Government: The UK Sanctions List