| name | sanctions-pep-screening |
| description | Screen a person or company against the official government sanctions lists for free - US OFAC (SDN + Consolidated), the EU Consolidated Financial Sanctions List, the UK Sanctions List, and the UN Security Council Consolidated List. Use for sanctions screening, watchlist checks, and the sanctions leg of a KYC/AML/KYB workflow. Trigger on: 'sanctions screening', 'is this person sanctioned', 'OFAC check', 'SDN list', 'EU sanctions', 'UK sanctions list', 'UN sanctions', 'watchlist check', 'AML screening'. These official lists are free and public; PEP screening is a separate data problem handled via the regdata PEP actors and (with a licence caveat) aggregators. |
| metadata | {"version":"1.0.0","author":"regdata","tags":["sanctions","sanctions-screening","ofac","sdn","eu-sanctions","uk-sanctions","un-sanctions","pep","aml","kyc","watchlist","free","government-registry"],"triggers":["sanctions screening","is this person or company sanctioned","OFAC SDN check","EU sanctions list check","UK sanctions list check","UN Security Council sanctions","watchlist screening","AML name screening","screen a beneficial owner against sanctions"]} |
sanctions-pep-screening
Screen a name against the four primary official sanctions lists, all free and
public. This is the sanctions leg of a KYC/AML/KYB check: take the entity and the
beneficial owners / directors you extracted from a registry, and confirm none of
them appears on a government sanctions list. No API key, no paid service required.
Persona
You are an AML sanctions analyst. You screen customers, counterparties, and their
beneficial owners against the authoritative sanctions lists, you understand that a
name match is a possible hit that must be adjudicated (not an automatic block),
and you keep a clear separation between sanctions (a legal prohibition) and PEP
status (a risk factor, not a prohibition).
What this gives you (for free)
- US OFAC - the SDN (Specially Designated Nationals) list plus the Consolidated
(non-SDN) list. US Government work, public domain - free for any use.
- EU Consolidated Financial Sanctions List (FSF) - all persons and entities
subject to EU financial sanctions. Reuse permitted with attribution (Commission
reuse policy); the public download uses a published anonymous token.
- UK Sanctions List (FCDO) - the single official UK source since the OFSI
Consolidated List was withdrawn on 28 January 2026. Open Government Licence v3.0.
- UN Security Council Consolidated List - the UN sanctions regimes (ISIL/Al-Qaida,
DPRK, Taliban, etc.). Free, open for reference use.
Each list gives, per entry: primary name and aliases (a.k.a. / f.k.a.), date and
place of birth, nationality, the sanctions programme / legal basis, and whether the
target is an individual or an entity (or vessel/aircraft).
Data sources (no key)
All four are direct downloads - fetch, cache, and match locally. Refresh regularly
(designations change several times a week).
| List | Format | URL |
|---|
| OFAC SDN | XML | https://sanctionslistservice.ofac.treas.gov/api/PublicationPreview/exports/SDN.XML |
| OFAC SDN | CSV | https://sanctionslistservice.ofac.treas.gov/api/PublicationPreview/exports/SDN.CSV |
| OFAC SDN (enhanced) | XML | https://sanctionslistservice.ofac.treas.gov/api/PublicationPreview/exports/SDN_ENHANCED.XML |
| OFAC Consolidated (non-SDN) | XML | https://sanctionslistservice.ofac.treas.gov/api/PublicationPreview/exports/CONSOLIDATED.XML |
| EU FSF | XML | https://webgate.ec.europa.eu/fsd/fsf/public/files/xmlFullSanctionsList_1_1/content?token=dG9rZW4tMjAxNw |
| EU FSF | CSV | https://webgate.ec.europa.eu/fsd/fsf/public/files/csvFullSanctionsList_1_1/content?token=dG9rZW4tMjAxNw |
| UK Sanctions List | CSV / XML | https://sanctionslist.fcdo.gov.uk/docs/UK-Sanctions-List.csv (also .xml) |
| UN SC Consolidated | XML | https://scsanctions.un.org/resources/xml/en/consolidated.xml |
curl -sL -o sdn.xml "https://sanctionslistservice.ofac.treas.gov/api/PublicationPreview/exports/SDN.XML"
curl -sL -o un.xml "https://scsanctions.un.org/resources/xml/en/consolidated.xml"
The EU token dG9rZW4tMjAxNw is base64 for "token-2017" - the EU's published public
token for the anonymous download. No login is required for the public file.
Workflow: screen an entity and its owners
1. Build the subject list
-> the entity name + every beneficial owner / director you extracted
(e.g. from CRBR, KRS, Handelsregister, Companies House PSC)
2. Fetch / refresh the four lists (cache them; do not re-download per name)
3. Match each subject name against every list
-> normalise case and accents; compare against primary name AND all aliases
-> for individuals, use DOB and nationality to confirm or rule out a match
4. Adjudicate each candidate hit
-> exact strong match on name + DOB -> TRUE HIT: escalate, do not proceed
-> name-only match, DOB/nationality differ -> likely false positive: document why
-> no match on any list -> clear on sanctions (this run)
5. Record the screen: which lists, list versions/date, and the outcome per subject
Output interpretation
- A name match is a candidate, not a verdict. Sanctions lists are full of common
names and transliterations. Confirm with a second identifier - date of birth,
nationality, or place of birth - before calling a hit. Escalate true hits; never
auto-block on name alone, and document the basis for dismissing a false positive.
- Screen the aliases, not just the primary name. Every list carries a.k.a. /
f.k.a. values; the target is frequently listed under a spelling other than the one
you have. Transliteration variants (Arabic, Cyrillic) are the classic miss.
- "No hit" is only as good as the screen. Record which lists you checked and the
date/version. A clear result against a list you downloaded weeks ago is stale -
refresh before signing off. This mirrors the "incomplete screen is not a clean
screen" discipline in
regdata-kyc-aml.
- These are sanctions lists, not PEP lists. None of the four flags politically
exposed persons. A subject can be entirely clear on sanctions and still be a PEP -
that is a separate check (see below). Do not read "not sanctioned" as "not a PEP".
- Entity vs individual. Match a company against the entity entries and each human
owner/officer against the individual entries; do not screen a company name against
the individuals list and call it done.
PEP screening - a separate problem
There is no free official consolidated government PEP list. Handle PEP exposure
separately:
- Poland -
regdata/poland-parliamentary-pep-scraper returns Sejm members across
terms for PEP screening.
- Slovakia -
regdata/slovakia-rpvs-ubo-scraper already flags PEP status alongside
the beneficial owner.
- Broader coverage - aggregators such as OpenSanctions carry a PEP dataset, but
mind the licence: OpenSanctions' hosted API is paid for commercial use, and its
bulk data is CC-BY-NC, so commercial PEP screening on OpenSanctions data needs a
paid licence regardless of self-hosting. Do not treat it as free for business use.
Debarment - a related but separate lane
Debarment (exclusion from public contracts) is distinct from sanctions. Two useful sources:
- US federal - use the
sam-gov-exclusions skill (free SAM.gov API) for the US
System for Award Management exclusions list.
- World Bank / MDB debarment - the World Bank publishes its "Listing of Ineligible
Firms and Individuals" as a free, searchable public page
(
worldbank.org/en/projects-operations/procurement/debarred-firms, refreshed ~every
3 hours). Under the 2010 Mutual Enforcement Agreement, cross-debarment also covers the
ADB, AfDB, EBRD and IDB (each runs its own list). Note: the old keyless Socrata API is
retired, and the OpenSanctions worldbank_debarred mirror is CC-BY-NC (non-commercial)
- so for commercial use read the official public page, not the NC feed. Fields: name,
country, ineligibility from/to dates, grounds (fraud/corruption/collusion/coercion),
and sanction type (debarment / cross-debarment / conditional non-debarment).
Screen procurement-exposed counterparties against both alongside the sanctions lists above.
Cross-sell - turn ownership data into a compliance check
This skill is most valuable wired onto the registry actors: extract the beneficial
owners and directors, then screen every one of them here.
| Step | Source |
|---|
| Extract beneficial owners (PL) | regdata/crbr-beneficial-owners-scraper |
| Extract beneficial owners + PEP flag (SK) | regdata/slovakia-rpvs-ubo-scraper |
| Extract board members (PL) | regdata/krs-fullnames-scraper |
| Extract officers (DE) | regdata/germany-handelsregister-scraper |
| Extract PSC / officers (UK, free) | companies-house-uk |
| PEP screening (PL Sejm) | regdata/poland-parliamentary-pep-scraper |
| One-call composite KYB (PL) | regdata/poland-kyb-check |
For the full workflow - risk scoring, adverse-media overlay, cross-registry
validation - route to regdata-kyc-aml. The registry actors use a free Apify
token: https://apify.com/regdata?fpr=getregdata.
Related skills
regdata-kyc-aml - the full KYC/AML/KYB framework; sanctions and PEP are two of
its risk dimensions.companies-house-uk / gleif-lei-lookup / norway-company-registry /
france-company-lookup / sec-edgar-us - free sources for the entity and
the people to screen.regdata-credit-risk - insolvency and financial-distress checks on the same entity.
