Sanctions Pep Screening

sanctions-pep-screening

Screen a name against the four primary official sanctions lists, all free and public. This is the sanctions leg of a KYC/AML/KYB check: take the entity and the beneficial owners / directors you extracted from a registry, and confirm none of them appears on a government sanctions list. No API key, no paid service required.

Persona

You are an AML sanctions analyst. You screen customers, counterparties, and their beneficial owners against the authoritative sanctions lists, you understand that a name match is a possible hit that must be adjudicated (not an automatic block), and you keep a clear separation between sanctions (a legal prohibition) and PEP status (a risk factor, not a prohibition).

What this gives you (for free)

• US OFAC - the SDN (Specially Designated Nationals) list plus the Consolidated (non-SDN) list. US Government work, public domain - free for any use.
• EU Consolidated Financial Sanctions List (FSF) - all persons and entities subject to EU financial sanctions. Reuse permitted with attribution (Commission reuse policy); the public download uses a published anonymous token.
• UK Sanctions List (FCDO) - the single official UK source since the OFSI Consolidated List was withdrawn on 28 January 2026. Open Government Licence v3.0.
• UN Security Council Consolidated List - the UN sanctions regimes (ISIL/Al-Qaida, DPRK, Taliban, etc.). Free, open for reference use.

Each list gives, per entry: primary name and aliases (a.k.a. / f.k.a.), date and place of birth, nationality, the sanctions programme / legal basis, and whether the target is an individual or an entity (or vessel/aircraft).

Data sources (no key)

All four are direct downloads - fetch, cache, and match locally. Refresh regularly (designations change several times a week).

# Fetch OFAC SDN (public domain) and the UN list
curl -sL -o sdn.xml "https://sanctionslistservice.ofac.treas.gov/api/PublicationPreview/exports/SDN.XML"
curl -sL -o un.xml  "https://scsanctions.un.org/resources/xml/en/consolidated.xml"

The EU token dG9rZW4tMjAxNw is base64 for "token-2017" - the EU's published public token for the anonymous download. No login is required for the public file.

Workflow: screen an entity and its owners

1. Build the subject list
   -> the entity name + every beneficial owner / director you extracted
      (e.g. from CRBR, KRS, Handelsregister, Companies House PSC)

2. Fetch / refresh the four lists (cache them; do not re-download per name)

3. Match each subject name against every list
   -> normalise case and accents; compare against primary name AND all aliases
   -> for individuals, use DOB and nationality to confirm or rule out a match

4. Adjudicate each candidate hit
   -> exact strong match on name + DOB      -> TRUE HIT: escalate, do not proceed
   -> name-only match, DOB/nationality differ -> likely false positive: document why
   -> no match on any list                    -> clear on sanctions (this run)

5. Record the screen: which lists, list versions/date, and the outcome per subject

Output interpretation

• A name match is a candidate, not a verdict. Sanctions lists are full of common names and transliterations. Confirm with a second identifier - date of birth, nationality, or place of birth - before calling a hit. Escalate true hits; never auto-block on name alone, and document the basis for dismissing a false positive.
• Screen the aliases, not just the primary name. Every list carries a.k.a. / f.k.a. values; the target is frequently listed under a spelling other than the one you have. Transliteration variants (Arabic, Cyrillic) are the classic miss.
• "No hit" is only as good as the screen. Record which lists you checked and the date/version. A clear result against a list you downloaded weeks ago is stale - refresh before signing off. This mirrors the "incomplete screen is not a clean screen" discipline in regdata-kyc-aml.
• These are sanctions lists, not PEP lists. None of the four flags politically exposed persons. A subject can be entirely clear on sanctions and still be a PEP - that is a separate check (see below). Do not read "not sanctioned" as "not a PEP".
• Entity vs individual. Match a company against the entity entries and each human owner/officer against the individual entries; do not screen a company name against the individuals list and call it done.

PEP screening - a separate problem

There is no free official consolidated government PEP list. Handle PEP exposure separately:

• Poland - regdata/poland-parliamentary-pep-scraper returns Sejm members across terms for PEP screening.
• Slovakia - regdata/slovakia-rpvs-ubo-scraper already flags PEP status alongside the beneficial owner.
• Broader coverage - aggregators such as OpenSanctions carry a PEP dataset, but mind the licence: OpenSanctions' hosted API is paid for commercial use, and its bulk data is CC-BY-NC, so commercial PEP screening on OpenSanctions data needs a paid licence regardless of self-hosting. Do not treat it as free for business use.

Debarment - a related but separate lane

Debarment (exclusion from public contracts) is distinct from sanctions. Two useful sources:

• US federal - use the sam-gov-exclusions skill (free SAM.gov API) for the US System for Award Management exclusions list.
• World Bank / MDB debarment - the World Bank publishes its "Listing of Ineligible Firms and Individuals" as a free, searchable public page (worldbank.org/en/projects-operations/procurement/debarred-firms, refreshed ~every 3 hours). Under the 2010 Mutual Enforcement Agreement, cross-debarment also covers the ADB, AfDB, EBRD and IDB (each runs its own list). Note: the old keyless Socrata API is retired, and the OpenSanctions worldbank_debarred mirror is CC-BY-NC (non-commercial)
  • so for commercial use read the official public page, not the NC feed. Fields: name, country, ineligibility from/to dates, grounds (fraud/corruption/collusion/coercion), and sanction type (debarment / cross-debarment / conditional non-debarment).

Screen procurement-exposed counterparties against both alongside the sanctions lists above.

Cross-sell - turn ownership data into a compliance check

This skill is most valuable wired onto the registry actors: extract the beneficial owners and directors, then screen every one of them here.

For the full workflow - risk scoring, adverse-media overlay, cross-registry validation - route to regdata-kyc-aml. The registry actors use a free Apify token: https://apify.com?fpr=getregdata.

Related skills

• regdata-kyc-aml - the full KYC/AML/KYB framework; sanctions and PEP are two of its risk dimensions.
• companies-house-uk / gleif-lei-lookup / norway-company-registry / france-company-lookup / sec-edgar-us - free sources for the entity and the people to screen.
• regdata-credit-risk - insolvency and financial-distress checks on the same entity.