Eight Sanctions Lists, and Where PEP Fits: What a Complete Screen Covers

A counterparty that is clean on one sanctions list can be designated on another. Sanctions authorities do not maintain a single shared list, and they do not move in lockstep. An entity can be listed by one jurisdiction weeks or months before another picks it up, and some are listed by one authority and never by the rest. Screening against a single source, even a major one, leaves a gap that a designated party can walk straight through.

A complete screen runs the major authorities together, with matching that catches aliases and near-spellings rather than only exact strings. Industry practice also pairs that with a politically exposed persons check, which is a different question answered from a different dataset.

To be explicit about what this article describes and what OilFlow does: OilFlow screens the eight sanctions lists below. OilFlow does not currently screen PEP. The PEP section here describes industry practice, not a capability we ship.

The eight lists

1. OFAC SDN (United States). The Specially Designated Nationals and Blocked Persons list, maintained by the US Treasury's Office of Foreign Assets Control. The most widely referenced sanctions list, but only one of OFAC's own, and only one country's.

2. OFAC Consolidated (non-SDN). OFAC's other listings, including sectoral and program-specific designations that do not sit on the SDN list. A party can be restricted under these without appearing on the SDN list at all, so screening SDN alone misses them.

3. UN Consolidated. The United Nations Security Council consolidated sanctions list. The baseline that many national regimes implement, but with its own scope and timing.

4. EU Consolidated. The European Union's consolidated list of persons, groups, and entities subject to EU financial sanctions. Binding across member states and not identical to the US or UN lists.

5. UK HMT / OFSI. The UK's consolidated list, maintained by the Office of Financial Sanctions Implementation within HM Treasury. Since the UK runs an autonomous regime, its listings diverge from the EU's.

6. Canada SEMA. Listings under Canada's Special Economic Measures Act and related regulations.

7. Australia DFAT. The Australian Department of Foreign Affairs and Trade consolidated list.

8. Switzerland SECO. Sanctions administered by the State Secretariat for Economic Affairs.

No two of these are identical, and the differences are the point. Coverage gaps between authorities, and the lag between one listing a party and the next following, are exactly where a counterparty that "passed sanctions" turns out to be designated somewhere that was not checked.

Where PEP fits, and what OilFlow does not do

A sanctions screen tells you whether a party is restricted. A politically exposed persons check tells you whether a party, or someone close to them, holds or held a position that raises the risk of bribery or corruption: senior government officials, military leadership, state-enterprise executives, and their close associates and family.

A PEP match is not a block the way a sanctions hit is. It is a risk flag that calls for enhanced due diligence. Compliance programs commonly run it alongside sanctions so elevated-risk cases surface in the same pass.

OilFlow does not currently screen PEP. The PEP dataset is not indexed and the check is not shipped, so a PEP screen has to come from another source in your stack. We say so rather than implying coverage we do not have.

Why matching is the hard part

Running eight lists is necessary but not sufficient if the matching is naive. Sanctioned parties rarely present a clean exact-string match to a list entry. Names are transliterated differently, entities operate under aliases, and small spelling variations defeat a literal lookup.

A usable screen matches on more than the exact string: known aliases and alternate spellings, and fuzzy variants that catch transliteration and typo-level differences, while controlling for the false positives that aggressive fuzzy matching produces. Too literal and you miss the designated party hiding behind an alias. Too loose and every screen drowns in noise. The value is in the calibration.

Where the screen sits in a deal

Sanctions screening answers "is this party restricted." It is one half of a complete pre-deal read. The other half is whether the trade can legally happen at all on its corridor, which is a different question answered by a tradability matrix: product tradability, payment terms, and license requirements for the origin and destination.

A party can clear all eight lists while the trade is still barred because the product cannot move that corridor. And a corridor can be wide open while a beneficial owner is designated. Running both, on the parties and on the corridor, is what a real clearance check is.

Using it as an API

OilFlow runs the eight-list sanctions screen as part of its counterparty KYC API and inside the pre-deal clearance read, with alias and fuzzy matching and a fail-closed posture: if the screen cannot complete, the counterparty does not pass. PEP is not part of it. It returns structured results you can gate a workflow on rather than a PDF a human has to read.

PEP screening is not shipped. The API reports coverage=sanctions_only, which means a politically exposed person is surfaced only where that person is also designated on one of the eight lists. Read the PEP section above as what a complete programme requires, not as what this API returns today. It is on the roadmap as a review-tier signal carrying an explicit coverage disclosure, never as a determination.

To try it on a real name, run a single counterparty through the free check first, or paste a proposed deal at /predeal for the full clearance read. To build against the screen directly, the API documentation and a free sandbox key are the starting point, no card required.