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Editorial illustration: documents and identifiers for partner verification
Editorial illustration

Due diligence guide · sources and identifiers

Check a potential sanctions-list match.

A similar name in a sanctions search is a candidate for review. A useful record preserves the correct list, compared identifiers, applicable text and decision rationale. No search result alone authorises a transaction.

Published 6 October 2026Updated 6 October 2026

At a glance

Four rules for a useful review.

  • Select regimes relevant to the transaction.
  • Compare identifiers as well as names.
  • Retain list version and search settings.
  • Ask the appropriate function to assess restrictions.

Step-by-step method

A reproducible path from question to conclusion.

  1. 1

    Define the transaction

    Record the contracting and paying parties, countries involved, goods or services and required decision. Name screening does not cover every potentially applicable restriction.

  2. 2

    Identify the exact entity

    Obtain the legal name, known aliases and available company identifiers. For a person, compare only necessary, lawfully obtained information. Preserve discrepancies rather than removing them.

  3. 3

    Use current sources

    Consult official portals for the selected regimes. The UK Sanctions List has been the current UK source since 28 January 2026; the former OFSI consolidated list is no longer updated.

  4. 4

    Assess each candidate

    Compare names, aliases, countries and published identifiers. Record agreements and contradictions. A fuzzy score assists name searching; it is not a legal assessment.

  5. 5

    Document and refer

    Retain the result and associated text. Refer unresolved matches, ownership or control issues and transaction restrictions to compliance or qualified counsel before proceeding.

Different lists have different scopes

The EU consolidated financial sanctions list supports research into persons, groups and organisations subject to those measures. Read it alongside published legal acts and relevant sectoral restrictions. No match in that list is not an exhaustive check of EU restrictions.

The OFAC tool compares names against SDN and consolidated non-SDN lists. Fuzzy searching can return a namesake. Retain the settings and do not interpret a displayed score as the probability that your counterpart is the designated person.

Keep matches and contradictions together

Create a row for each candidate: source, list identifier, searched name, aliases, country, matching elements, contradictions and resolution status. Two transliterations do not automatically identify two different people.

A matching company identifier can strengthen a match; identical names with incompatible identifiers can suggest a namesake. Missing information remains explicitly unknown. Request the relevant document through an appropriate channel rather than filling gaps by assumption.

Date the decision and define review triggers

Record consultation time, available list date or version and associated legal text. Separate designation date from the date you found it. State which regimes were examined and which were outside scope.

A new counterpart or change in ownership, country, payment route or service can justify another check. Assign an owner and a review trigger suitable for the case instead of inventing a universal interval.

Produce a usable decision record

The note may state: no match identified within the named lists and settings; potential match unresolved; or documented match referred for assessment. It must also describe search limitations and remaining transaction checks.

Search results do not replace applicability, ownership and control, exception or licence assessments. Sensitive decisions require the responsible function and current legal texts.

Common pitfalls

Four shortcuts that weaken the result.

Using a historical list

An accessible old file may no longer receive new designations.

Closing on name alone

Compare available identifiers before resolving the result.

Treating no match as clearance

Name lists do not cover all restrictions.

Losing search settings

An unrecorded search cannot be reproduced.

Practical questions

Frequently asked questions.

Is the OFSI list sufficient in 2026?

For current UK designations, use the UK Sanctions List. The OFSI consolidated list stopped being updated on 28 January 2026.

Does a high search score prove identity?

No. It guides name comparison; resolution requires available identifiers and context.

Does a negative search validate a payment?

No. It describes a result within the lists and settings used; other restrictions and payment legitimacy still need assessment.

Public references

Commission européenne — sanctions. Listes financières et textes de référence / Financial lists and legal references.

GOV.UK — UK Sanctions List, 2026. Changement de source britannique et identifiants / UK source transition and identifiers.

OFAC — Sanctions List Search. Recherche approchée et limites / Fuzzy search and limitations.

Editorial scope

Published by Internet Intelligence Service on 6 October 2026. Last content update: 6 October 2026. This educational guide describes a lawful, defensive method. It is not legal advice, an emergency service or authority instruction.

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