MSWiA · European Union · UN · OFAC (USA) · UK and other jurisdictions
Sanctions lists - verification and screening of business partners
Sanctions compliance isn't a one-time check, it's an ongoing process. Lists are updated continuously, and the prohibition on making funds available to sanctioned entities applies to every company. PartnerPal verifies a business partner and all associated individuals in a single request, monitors them continuously, and documents every check for audit purposes.
HOW SANCTIONS LIST SCREENING WORKS
From official list to internal business decision
MSWiA
EU
UN
OFAC
UK
other jurisdictions
01
Sources
Baseline: MSWiA, EU, UN, OFAC, and UK. The scope can include additional lists based on your risk policy.
02
Comparison
We check identifiers, exact names, and similar spelling variants.
03
Certainty
A match is assigned a status level: exact, highly likely, or likely.
04
Decision
The team sees list data, resolves the match, and leaves an audit trail.
Monitoring re-screens the same entities after list updates - a match can occur at any point in the process.
What are sancions lists
Sanctions lists are registries published by states and international organizations listing individuals, companies, and organizations subject to restrictive measures - most commonly the freezing of funds and a prohibition on making money or economic resources available to them. Being listed means that business relations with such an entity may be prohibited or require special authorization.
For a company operating in Poland, the national list and EU lists are of primary importance. In trade with partners from the United States and the United Kingdom, or when settling transactions in their currencies, those countries' lists often come into play as well.
Below are the five primary sources where sanctions screening typically begins in the EU and AML processes. This is not an exhaustive list - PartnerPal can also monitor other national, sectoral, and jurisdictional lists.
List
Issued by
What it includes
Official source
List of individuals and entities subject to sanctions (MSWiA)
Minister responsible for internal affairs, pursuant to the Act of April 13, 2022
Individuals and entities subject to sanctions in Poland in connection with Russia's aggression against Ukraine, including measures such as the freezing of funds and exclusion from public procurement
EU Consolidated Financial Sanctions List
European Commission, based on Council of the European Union decisions
Individuals, groups, and entities subject to EU financial sanctions across all EU sanction regimes
UN Security Council Consolidated List
UN Security Council
Individuals and entities subject to
UN sanctions, including those
related to terrorism and weapon proliferation
OFAC: SDN List and Non-SDN Lists
Office of Foreign Assets Control, US Department of the Treasury
SDN: individuals and entities whose assets subject to US jurisdiction are blocked. Non-SDN: includes sectoral restrictions
Each list has its own format, its own spelling of names, and its own update schedule. Manually checking even just the core five requires separate searches across different formats. With a broader scope of lists, the number of searches grows even faster.
Who needs to be checked - why the company name alone is not enough
Sanctions lists primarily contain individuals. The company you are dealing with may not appear on any list under its own name, yet it might be owned or controlled by someone who is listed. Checking only the company name yields a clean result and a false sense of security.
This is not just a matter of caution. EU restrictive measures also extend to assets owned or controlled by listed individuals, which in practice includes companies in which such a person holds more than 50% of the shares or exercises control. US OFAC applies a similar 50 Percent Rule: a company owned in the aggregate, directly or indirectly, 50 percent or more by one or more SDN-listed persons is treated as sanctioned, even if the entity itself does not appear on the list.
That is why, during every verification, PartnerPal screens the entity and its related parties against the core set of lists as well as additional client-configured sources:
- the company itself
- members of the management board and commercial proxies,
- shareholders and owners,
- members of the supervisory board,
- ultimate beneficial owners (UBOs),
- sole proprietors registered in CEIDG,
- capital-linked entities and further tiers of the ownership structure, down to natural persons.
All of these individuals are then added to ongoing monitoring. If a member of your supplier's supervisory board is added to a list a few weeks later, you will learn about it from an alert, not from the press.
How we check -
a match versus fuzzy matching
The diagram below illustrates how PartnerPal moves from the strongest signal to a result with a confidence level, without overwhelming your team with random similarities.
MATCHING MECHANISM
From the strongest signal to a result with a confidence level
01
Identifiers
Company registration numbers and personal identifiers, if the list contains them. A matching number provides the strongest signal.
02
Exact name
Comparing the full company name or first and last name without expanding the result to include similar variants.
03
Similar names
Typos, missing Polish diacritics, swapped name order, and transliterations. For companies, legal forms are omitted.
A gate for natural persons
Date of birth reinforces a match, while a conflicting date rules it out. This mechanism reduces false positives and keeps teams from wasting time investigating individuals who share a common name.
Noise-free results
exact
highly likely
likely
We do not show random similarities. The user receives data from the list and makes the final decision.
What to do when a match occurs
Compare the data
Check whether the identifiers, date of birth, and other entry details match.
Check the source
See which list the match originates from, and compare the entry against the official source.
Resolve a false positive
If it is a coincidence of names, reject the match in PartnerPal. The system requires a justification, and the decision is recorded in the audit trail with a timestamp and author.
Escalate a confirmed match
Hold further steps, such as signing an agreement or issuing a payment, and escalate the matter to the compliance team or legal counsel.
The audit trail answers the question that comes up during every audit: who dismissed a match as a false positive, when, and why. Instead of notes scattered across emails and Excel spreadsheets, you have a single history of decisions for your entire portfolio.
Sanctions monitoring -
lists change more frequently than contracts
The European Union regularly adopts new sanctions packages, while national and international lists are updated on an ongoing basis. PartnerPal monitors a core set of sources and can expand it to include additional lists specific to the client's business. A one-off check becomes outdated as soon as the next day.
How monitoring works in PartnerPal:
1
Source updates
Sanctions lists and configured sources are automatically synchronized before the next operational day begins.
2
Rescreening
Every business day, the system rechecks monitored companies, management boards, shareholders, and UBOs.
3
Team alert
When a new match occurs or an existing one becomes stronger, the designated individuals receive an email alert.
4
Monitoring expansion
Individuals and companies outside standard verification, such as foreign clients, can be added to the monitored entities.
5
Review list
The team can see monitored entities, matches, and cases requiring a decision all in a single view.
Who sanctions apply to
The prohibition against making funds or economic resources available to individuals and entities on sanctions lists does not apply exclusively to banks. EU sanctions regulations are directly applicable across the EU, and the Polish Act of April 13, 2022, on special solutions to counteract supporting aggression against Ukraine and to protect national security provides for severe administrative penalties for violations. At the same time, the regulations do not impose a one-size-fits-all screening procedure on every company; the manner and scope depend on the risk level and the entity's status.
For obliged entities, the AMLR Regulation (EU) 2024/1624, applicable from July 10, 2027, further reinforces this framework. It explicitly requires verifying whether a customer and their ultimate beneficial owners are subject to targeted financial sanctions.
In practice, sanctions lists are most commonly checked by:
Compliance and AML
Compliance and AML departments in obliged entities, where sanctions screening is an integral part of customer due diligence (CDD) measures.
Procurement
Procurement departments prior to placing an initial order and upon any changes in a supplier's ownership structure.
Financing
Factoring, leasing, and corporate financing prior to the disbursement of funds to a client.
Advisors and foreign trade
Accounting firms, advisory practices, and companies engaged in international trade, particularly those dealing with non-EU partners or complex ownership structures.
Manually vs. in PartnerPal
Scope
Manually, in official search engines
PartnerPal
Lists
Multiple separate websites, each in a different format
Core and additional lists screened in a single request
Related parties
Every person must be searched individually
Management board, commercial proxies, shareholders, supervisory board, and UBOs screened automatically
Ownership strucrure
Manually navigating through KRS records of successive companies
Consecutive levels of the ownership structure retrieved from KRS
Name variants
Spelling variations must be devised manually
Phonetic and fuzzy matching with a designated confidence level
Changes to lists
Checks must be repeated manually
Daily business-day monitoring with email alerts
Proof of check
Screenshots and manual notes
PDF report with source links and an audit decision trail
Batch processing
One company at a time
File import via NIP numbers or integration via API
Report and proof of check
Every verification generates an auditable PDF report with links to the original sources. It clearly shows when the check was performed and what the result was. Together with the false positive decision log, this provides a documented audit trail ready to present to auditors, banks, or the board of directors.
FAQ
Which sanctions lists does PartnerPal check?
Five lists: the Polish MSWiA list, the EU Consolidated Financial Sanctions List, the UN Security Council Consolidated List, the US OFAC lists (SDN and Non-SDN), and the UK Sanctions List. All of them are automatically updated every night. Screening can be expanded to include additional lists, contact us to discuss the scope.
Do you check management board members and ultimate beneficial owners?
Yes. When verifying by NIP, we check not only the company itself, but also the management board, commercial proxies, shareholders, supervisory board, UBOs, and further levels of the ownership structure from the National Court Register (KRS).
How often are the sanctions lists updated in PartnerPal?
We synchronize lists automatically every night. Monitored companies and individuals are rescreened every business day, and designated teams receive email alerts upon any new or higher-confidence match.
What does "fuzzy matching" mean?
This is a result where the name does not match character for character, but is highly similar: a different transliteration from Cyrillic, missing diacritics, or a different legal form. Every such match includes a confidence score and requires review.
How do I dismiss a false positive, and does it leave an audit trail?
You dismiss the match in PartnerPal by providing a justification. The decision is recorded in the audit trail with a timestamp, author, and comment, allowing you to reconstruct at any time who made the decision and why.
Can I check multiple companies at once via API?
Yes. You can import a file with NIP numbers to check your entire portfolio in a single batch, or integrate PartnerPal directly with your system via API. Checked companies and associated individuals can immediately be added to continuous monitoring.
Is screening counterparties against sanctions lists mandatory?
The prohibition against making funds or economic resources available to listed individuals and entities applies to everyone, but the regulations do not impose a single, mandatory screening procedure on every company. Obliged entities screen clients and beneficial owners as part of their AML procedures, and as of July 10, 2027, this is explicitly required by the AMLR Regulation.
Is a PartnerPal report sufficient as documentation of a check?
The PDF report serves as proof of verification: it indicates the date, scope, and result, while linking directly to official sources. The specific documentation required depends on the company's status. Obliged entities define these requirements within their internal AML procedures.
Screen a counterparty against sanctions lists
Enter a NIP number or import a company list. PartnerPal checks the core set of sources, displays the results for the company and associated parties, and then allows you to place them under continuous monitoring - including across additional lists.
Last updated on September 29th, 2026.