Screening only the company
Without officers and shareholders, risk that comes through ownership and control stays invisible.
How-to · Compliance
How to screen a company, its officers and shareholders against sanctions lists
Sanctions screening means searching the company, its officers, shareholders and beneficial owners on the relevant sanctions lists. Choose the lists by the countries your transaction is connected to; for Türkiye include the asset-freeze decisions under Laws 6415 and 7262. A matching name is not an identification: confirm it with date of birth, nationality and address, and keep a record.
- Six steps
- Table of lists
- Record and re-screening
Last reviewed · Ulawk editorial team
Method
Sanctions screening in six steps.
Screening is never one-off: lists and companies change.
A possible match is not a decision.
Turkish registry notices rarely carry dates of birth or nationality, so a name match must be confirmed with further information.
Decide whom to screen
The company, its board members or managers, its shareholders and its beneficial owners.
Choose the lists
The UN Security Council list; EU, UK or US lists where your transaction connects to them through persons, currency, goods or services; in Türkiye the asset-freeze decisions under Laws 6415 and 7262.
Prepare the names
Full trade name and former names; for individuals, spelling variants and transliterations (Turkish Ş/S, Ğ/G, Ç/C).
Apply the ownership rule
Under US practice a company owned 50% or more in aggregate by listed persons is blocked too; the EU applies an ownership and control test. You need the ownership chain.
Assess the match
Compare date of birth, nationality, address and identifiers; record a "not the same person" decision with reasons.
Keep the record and repeat
Screening date, names screened, lists, result and decision. Screen again when management or ownership changes and as lists are updated.
Lists
Which list, kept by whom.
The lists Ulawk updates every day. Sanctions lists and procurement or funding debarments are different types.
| List | Kept by | Type |
|---|---|---|
| UN Security Council Consolidated List | United Nations Security Council | Sanctions |
| EU consolidated financial sanctions list | Council of the European Union (list kept by the European Commission) | Sanctions |
| Specially Designated Nationals and Blocked Persons List (SDN) | US Department of the Treasury, Office of Foreign Assets Control (OFAC) | Sanctions |
| Consolidated Screening List (entries other than the SDN list) | US Departments of Commerce, State and the Treasury | Sanctions |
| UK Sanctions List | Foreign, Commonwealth & Development Office (FCDO) | Sanctions |
| Swiss sanctions list | State Secretariat for Economic Affairs (SECO) | Sanctions |
| Consolidated Canadian Autonomous Sanctions List | Global Affairs Canada | Sanctions |
| Australian Sanctions Consolidated List | Department of Foreign Affairs and Trade (DFAT) | Sanctions |
| Asset freeze list under the Foreign Exchange and Foreign Trade Act | Ministry of Finance of Japan | Sanctions |
| Asset freezes under Laws No. 6415 and 7262 | Financial Crimes Investigation Board (MASAK) | Sanctions |
| Capital markets trading bans | Capital Markets Board of Türkiye (SPK) | Capital markets trading ban |
| World Bank debarred firms and individuals | World Bank Group | Procurement and funding debarment |
| Sanctioned firms and individuals, including cross-debarments | Inter-American Development Bank | Procurement and funding debarment |
| Exclusion list for EU-funded contracts and grants (EDES) | European Commission | Procurement and funding debarment |
| Register of debarred and suspended companies (CEIS) | Office of the Comptroller General of Brazil (CGU) | Procurement and funding debarment |
| Companies penalised under Law 12,846/2013 (CNEP) | Office of the Comptroller General of Brazil (CGU) | Procurement and funding debarment |
Common mistakes
Four mistakes that weaken screening.
Most come from keeping the scope too narrow.
Skipping former names
A list may carry the company's former name or a foreign-language name.
No record
If you cannot show which lists were screened on which day, the screening cannot be proven.
Screening once
Lists change often; screen again at each transaction and each change.
With Ulawk
Sanctions screening with Ulawk
On the profile of a Turkish company you follow, the company, its officers and shareholders are screened on sanctions lists from: United Nations, European Union, United States, United Kingdom, Switzerland, Canada, Australia, Japan and Türkiye.
Possible matches
Results show the list, programme and entry ID as a possible match; similar names are not reported as matches. You review each one and can record "not the same person".
Screening record
Each record is a fresh screening at that moment: names, lists, result and your decisions as a PDF, verifiable later by its record number and content digest.
Bulk screening
Paste a list of names, screen it on all lists and download the result as CSV.
In the DD report
Sanctions and debarment screening is a section of the DD report.
Which sanctions lists should I screen?
At least the UN list and the lists of the countries your transaction connects to; in Türkiye, the asset-freeze decisions under Laws 6415 and 7262. Which lists apply depends on the parties, currency and goods.
Should I stop the transaction if a name matches?
Confirm the match first. A confirmed match stops the transaction and goes to compliance; in Türkiye the duty to comply with asset-freeze decisions comes from Laws 6415 and 7262.
How often should I re-screen?
At least at each new transaction, when management or ownership changes and at periodic review. Lists change often.
Is PEP screening the same as sanctions screening?
No. Checking for politically exposed persons is a separate customer due diligence step; sanctions screening does not cover it.
Official sources
- Financial Crimes Investigation Board of Türkiye (MASAK)masak.hmb.gov.tr↗
- Law No. 6415 (Turkish)mevzuat.gov.tr↗
- Law No. 7262 (Turkish)mevzuat.gov.tr↗
- UN Security Council Consolidated Listmain.un.org↗
- EU consolidated financial sanctions listsanctionsmap.eu↗
- Specially Designated Nationals and Blocked Persons List (SDN)sanctionssearch.ofac.treas.gov↗
- UK Sanctions Listsearch-uk-sanctions-list.service.gov.uk↗
This page is general information, not legal advice.
Related pages
Law firm, in-house legal or accounting team?
Bring your list of customers, suppliers and counterparties; in an intro meeting we show Ulawk with your own companies.
Screen with a record you can show.
Ulawk produces a fresh screening record every time, ready for the auditor.
Enterprise · 100+ companies
Request an intro meeting or a quote.
For more than 100 companies, team work, an API integration or the trademark and regulatory modules, we prepare a price for you.
- Try it with your own companies in a demo
- We upload your Excel list
- Help setting up API and webhook
Write to us:
[email protected]