Sanctions screening is the discipline of checking the people and entities you deal with against the lists maintained by the bodies that impose sanctions. For capital touching Zimbabwe, this is not optional housekeeping — Zimbabwe has been subject to targeted measures, and dealing with a listed party can carry serious consequences regardless of where the deal is booked.
The four perimeters
- OFAC (United States) — the Office of Foreign Assets Control maintains the Specially Designated Nationals (SDN) list and other consolidated lists. US sanctions can reach non-US persons through US-dollar clearing and US-nexus dealings.
- UN — the United Nations Security Council Consolidated List, which member states are obliged to implement.
- EU — the consolidated list of persons, groups and entities subject to EU financial sanctions.
- UK — the HM Treasury (OFSI) consolidated list of those subject to UK financial sanctions.
We screen the named counterparty and the parties connected to it — beneficial owners, controllers and key principals — against all four perimeters, using publicly available data as at the date of screening. Continuous screening means the check is repeated over the life of an engagement, because lists change and a party that was clear at onboarding may not stay clear.
What screening is — and is not
Screening is a point-in-time reference exercise against public lists. It surfaces matches and likely matches for a human to assess; it is not, by itself, a sanctions-compliance opinion or a clearance to proceed. Names are not unique, ownership can be opaque, and the legal question of whether a particular dealing is permitted is a matter for qualified sanctions counsel. The screen tells you where to look harder; it does not absolve the decision.
Screening information is provided for reference only. It is not legal advice and is not a sanctions-compliance determination. Where a dealing may engage a sanctions regime, engage qualified sanctions counsel before proceeding — the responsibility for compliance rests with the party doing the deal.
How it fits the engagement
Where screening is in scope, it is set out — with these limitations — in the Risk Advisory Engagement Letter, and the perimeter that was screened is recorded on the Political Risk Memorandum cover sheet so the reader knows exactly what was checked and as at when. Because screening exposes sensitive counterparty data, it is typically run under a one-way NDA from the disclosing party.