# Sanctions screening

**Sanctions screening is the check of customers, their beneficial owners and, where relevant, their counterparties against the lists of persons and entities subject to targeted financial sanctions, so that their assets are frozen and no funds are made available to them.** For a business customer, EU law also requires a check of whether sanctioned persons control it or own more than 50 % of it.

*Also called:* sanctions checks, restrictive-measures screening, list screening.

## Why it matters for PSPs and EMIs

A payment institution that onboards a sanctioned merchant, or a merchant controlled by a sanctioned person, makes funds available to that person with every settlement. Screening is therefore needed at onboarding, when lists change, and in transactions. The hard part is rarely the exact match; it is the possible match — a similar name with no identifier yet to confirm or exclude it.

## What the law says

- **Onboarding duty.** AMLR Art. 20(1)(d): verify whether the customer or its beneficial owners are subject to targeted financial sanctions and, for a legal-entity customer, whether sanctioned persons control it or have more than 50 % of its proprietary rights or a majority interest, individually or collectively.
- **What "targeted financial sanctions" means.** AMLR Art. 2(1)(49): asset freezes and prohibitions to make funds or other assets available, under Council decisions based on Article 29 TEU and Council regulations based on Article 215 TFEU. UN financial sanctions are defined in Art. 2(1)(50).
- **Keep checking.** AMLR Art. 26(4): verify regularly; for credit and financial institutions, also upon any new designation.
- **Business-wide view.** AMLR Art. 10(1): the business-wide risk assessment covers the risk of non-implementation and evasion of targeted financial sanctions.
- **Registers.** AMLD6 (Directive (EU) 2024/1640) Art. 10(9): central beneficial ownership registers must flag entities associated with sanctioned persons.
- **Controls.** EBA Guidelines EBA/GL/2024/14 on internal policies, procedures and controls to implement Union and national restrictive measures, applicable from 30 December 2025 and addressed also to payment and e-money institutions.
- **International standard.** FATF Recommendations 6 and 7.

## How ProofVolt handles it

ProofVolt checks sanctions before the customer is asked for anything. A possible match stays open until an officer resolves it with identifiers, and until then the receipt shows it as unresolved (for example, "Sanctions candidate on a director — unresolved").

## Related

- [Beneficial owner (UBO)](/glossary/beneficial-owner/)
- [Ongoing monitoring](/glossary/ongoing-monitoring/)
- [Adverse media](/glossary/adverse-media/)

Canonical: https://proofvolt.eu/glossary/sanctions-screening/