How sanctions and PEP screening is conducted
What the lists check, where false matches come from, and how to read the result
Updated 3 August 2026 · 8 min read
Screening appears to be a simple procedure: a name is checked against lists and the system produces a result. In practice, two opposite errors arise here. The first is blocking a normal transaction due to a match with a namesake. The second, far more dangerous, is missing a genuine match concealed behind an alternative spelling of a name or an ownership chain.
The guide explains how screening works: which lists exist and how they differ, how the control rule operates for companies linked to sanctioned persons, why transliteration of names creates a systemic problem, and how the context of each match is verified. PEP status is addressed separately: who falls under it, whether it extends to relatives, and how long it persists after leaving office.
This material is not a legal assessment of the applicability of sanctions regimes - that is provided by a lawyer in the relevant jurisdiction
Who this material is for
- for compliance officers
- for companies with international payments
- for clients who have faced a bank refusal
- for lawyers handling transactions
Questions covered in this guide
- which sanctions lists exist and how they relate to one another
- how the control rule works
- where false matches come from
- who is considered a PEP and for how long
- what to do when a match is found
Contents
- Map of lists and regimes
- The control rule and ownership chains
- Transliteration of names as a source of errors
- PEP: categories, relatives, timeframes
- Verifying the context of a match
- Actions after a match is identified
BLACKFILE does not remove data from independent databases and does not influence the decisions of banks or authorities.
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