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Sanctions screening in B2B trade: a practical guide for SMEs

Sanctions apply to every company that trades across borders, not only to banks and large corporates. Making funds or goods available to a sanctioned person can breach the law regardless of how small your business is. Screening, meaning checking a counterparty against sanctions lists, is a simple routine to run before every new relationship and whenever details change. This is a practical overview, not legal advice.

By Hiram Trade Editorial Desk

Published

6 min read

What sanctions mean in trade

In B2B trade you will mostly meet three types of measure:

  • asset freezes and bans on making funds available to listed persons and entities: you may not pay them, deliver goods to them or provide services, directly or indirectly;
  • sectoral and goods-based restrictions: bans on exporting or importing specific goods, technology and services to or from specific countries, whoever the counterparty is;
  • measures tied to places or vessels, such as port access bans on designated ships.

The first type is checked against name lists. The second requires knowing the tariff classification of your goods and where they are going.

Which lists to check

ListMaintained byWhere
EU consolidated financial sanctions listEuropean CommissionEU Sanctions Map, data file on data.europa.eu
UN Security Council Consolidated ListUnited NationsSecurity Council website
UK Sanctions ListUK Government (FCDO)gov.uk
Specially Designated Nationals (SDN) and other listsOFAC, US TreasurySanctions List Search
National lists, e.g. Poland's listPolish Ministry of Interior (MSWiA)gov.pl

Practical notes:

  • Since 28 January 2026 the UK Sanctions List has been the only source for UK designations, and the former OFSI Consolidated List of Asset Freeze Targets is no longer updated. If your screening tool still uses the old list, switch the source.
  • UN sanctions are implemented in the EU through Council regulations, but the UN publishes changes first, so check both.
  • US sanctions formally bind US persons, but US dollar payments pass through banks that screen against OFAC lists. A payment to an SDN-listed party can be blocked even if neither side is American.
  • For Philippine exporters: EU buyers and their banks will screen you and your owners, so keep ownership information ready and consistent.

Ownership and control

A company that is not on any list can still be caught. OFAC applies the 50 Percent Rule: an entity owned 50% or more, directly or indirectly, in aggregate by one or more blocked persons is itself treated as blocked, even if it is not listed. In the EU both ownership and control matter, and the Commission publishes guidance on how to assess them. So screen the owners and directors, not only the company name.

Screening step by step

  1. Collect data: full legal name and trade names, country, address, registration number, owners above your chosen threshold, directors and, for individuals, date of birth and nationality where available.
  2. Check the lists: use the official search tools or a tool fed by current source files. Include transliteration variants and aliases.
  3. Assess hits: compare each hit with identifying data (country, date of birth, registration number, address).
  4. Record the result: date, list and version, who checked, decision and reasoning.
  5. Repeat: lists change often. Re-screen before each new transaction and when the counterparty's details change.

False positives

Common names and generic company names generate many matches. A false positive is identified by mismatched identifiers: a different date of birth, country or registration number. Do not dismiss a hit just because the spelling differs slightly; lists include aliases and transliterations from Cyrillic, Arabic or Chinese scripts. If you are still unsure after comparison, ask the counterparty for further documents or take advice.

When to stop a deal

Pause and consult a lawyer when:

  • the counterparty, its owner or a representative is listed (confirmed match);
  • you cannot establish ownership and the counterparty refuses to explain it;
  • the goods fall into a category under an export or import ban for the country involved;
  • routing, unloading address or payer points to a sanctioned country even though the counterparty sits elsewhere;
  • requests to change consignee, payer or destination port arrive with no business logic.

With a confirmed match, do not alert the counterparty before taking legal advice. The EU Sanctions Map lists the competent national authorities for each Member State.

Goods-based restrictions: the Russia example

Council Regulation (EU) No 833/2014 bans exports and imports of many categories of goods in trade with Russia. These bans attach to the goods, not only to listed parties, and some provisions require contractual clauses prohibiting re-export to Russia when selling certain goods to third countries. If you sell machinery, electronics, chemicals or metals to third countries, check whether your CN code is covered.

Screening on Hiram

Hiram screens counterparties against EU, UN, UK and US (OFAC) sanctions lists. The result is a signal, not a legal assessment: if there is a match or unclear ownership, the decision is yours and your adviser's.

Checklist

  • Checked: EU, UN, UK Sanctions List, OFAC, plus any national list that applies to you.
  • Owners and directors screened, not just the company name.
  • Hits compared against identifying data.
  • CN code and destination checked for goods-based restrictions.
  • Result recorded with the date.
  • Re-screening before the next transaction.

To trade with counterparties that have been through sanctions screening, create a Hiram account.

Sources

This article is for information only and is not legal, tax or customs advice. Rules and rates change: check the current official sources or consult an adviser before you decide.

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