Sanctions screening

Screening does not stop at the contracting party. A supply chain holds the invoice recipient, the consignee, whoever collects the goods, the carrier and the beneficial owners behind a company, and any of them may be listed. A company can be caught even though its own name appears on no list, namely where a listed person controls it or holds a significant stake. Where exactly the line runs is for the competent authorities to judge case by case. When in doubt the question belongs before the delivery, not after it.

Nor is screening a one off exercise. The lists are updated continuously, so a check at the time of contract is not a check for the life of the contract. What counts is the position on the day of the transaction, and a new consignee, a new country of destination or a change of shareholder triggers a fresh check.

Only what was recorded can be evidenced: which list in which version was queried, with which search term, with which result and by whom. On a hit the consignment is held and the first question is whether this is a name match or the listed person. Only then is it clear whether the supply has to be withheld.

Most often only the invoice recipient is screened. On an export, however, a third party frequently sits at the end of the chain, appearing for the first time on the consignment note or in the collection order, and that is exactly where it is decided who actually receives the goods.

The second mistake is screening without a record. It was carried out, but nobody noted the date, the list and the result. Towards customs that is worth as much as no screening at all. And third, the ownership structure is readily ignored: an unremarkable company with a listed majority shareholder is itself blocked.