What is an International Sanctions Check?
The international sanctions check is a due diligence process used to identify individuals who hold prominent public positions or are associated with such individuals, as well as those who are subject to law enforcement restrictions or financial sanctions globally. These checks help organisations mitigate the risk of engaging in business with individuals who may be involved in corruption, money laundering, or other illicit activities.
At EBC Global, customers benefit from consolidating the Sanctions Check with a PEP (Politically Exposed Person) check to determine whether the person is exposed directly or indirectly through a close relationship with someone in a position of political power.
What are the Sources of an International Sanctions Check?
The sources typically include various databases and sanctions lists from around the world. These can include law enforcement lists, government sanctions lists, and financial regulator lists. Data is aggregated from multiple sources to ensure comprehensive coverage.
Some of main international sanction lists include:
- HM Treasury (UK),
- UN Security Council,
- EU,
- US Department of State,
- US Office of Financial Actions Control (OFAC).
Unlike government-managed sanctions lists, there is no single, comprehensive source for identifying Politically Exposed Persons (PEPs). Organisations that conduct PEP checks typically access multiple data sources from around the world. These sources can include law enforcement lists, government records, and specialised databases maintained by organisations focused on transparency and anti-corruption efforts. A data aggregator is used to consolidate the PEP data.
What Will an International Sanctions Check Tell You?
A sanctions check will inform you if an individual or entity is subject to any restrictive measures imposed by governments or international bodies. These measures can include asset freezes, travel bans, and trade restrictions. The search results will indicate the specific sanctions in place and the reasons for their imposition.
The PEP check identifies individuals who are (or were) senior officials in politics, government, state-owned enterprises, judiciary, banking, law enforcement, military, and religious institutions. In addition to these prominent individuals, their relatives, friends, and business associates can also be classified as Relatives and Close Associates (RCAs). This is because criminals may exploit these connections to exert influence or bribe the high-profile person.
How to Review the Results of a Sanction Search
When reviewing the results of a sanction search, it is important to:
- Verify the Identity: Ensure that the individual or entity in question matches the details provided in the search results.
- Check the Sanction Details: Understand the nature of the sanctions, including the type of restrictions and the issuing authority.
- Assess the Impact: Determine how the sanctions might affect your business relationship or transaction.
The actions you take based on the results of a sanction search are ultimately up to you and your organisation.
In some situations, the decision may be straightforward. For instance, if you are hiring a financial director, you would likely avoid candidates involved in financial fraud.
The key question to consider is: “Would this pose a problem for our company?” For example, would employing the child of a member of parliament create a conflict of interest?
Ruling Out Multiple Results/Profiles
To rule out multiple results or profiles, you should:
- Check any photograph included for likeness.
- Cross-Reference Information: Use additional identifiers such as date of birth, nationality, country of origin, and known associates to differentiate between individuals with similar names.
- Double check spellings, middle names, place of birth, passport stamps and visas.
- Check dates and references closely. Would it be implausible for the individual to have been involved at the time of the event?
- Consult Additional Sources: Look at other databases or records to confirm the identity and status of the individual or entity.
- Examine source links for date matches. For example, your candidate got married in 1977, but your candidate was born in 1970.
Organisations and employers are using this check to perform due diligence. Could your search or investigation benefit from additional background checks, such as an internet search, or social media screening? Where assurances must be sought, consider consulting a legal advisor or compliance expert.
Using EBC Global for Your Sanctions Search
EBC Global offers a comprehensive sanctions check that aggregates data from numerous international sources. By entering just a few details, you can obtain a concise report, with information obtained from thousands of databases; helping you to make informed decisions to protect your organisation.
This is a great example of a Sanctions and PEP check where the individual is listed under one variation of a name match on a Sanctions List, and under a slightly different name or alias as a PEP.
In this case, it is the same individual despite the differences in his names. View the Full Report Here!
EBC Global helps businesses stay compliant with regulatory requirements. By using our platform, you can ensure that your sanctions checks are thorough and up-to-date, To learn how EBC Global can help you with your international sanctions check (as well as other background checks), contact us today to book a demo.
For UK employers, there is information publicly available on the government website, such as The UK sanctions list, which provides under the Sanctions and Anti-Money Laundering Act 2018.
Additional Resources
