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Using Sanctions Screening

How to screen people, companies and whole files, what the results mean, and how to keep and check the records. Connecting your own systems? That's in the API docs.

Step by step

Start a trial

  1. Go to Start free trial.
  2. Enter your business, your name and your work email. If your company is registered, pick it from the list as you type.
  3. If someone else will connect your systems, add your developer's name and email: they'll get an API key of their own.
  4. Enter a card. Nothing is charged during the 14-day trial, which includes 500 checks.
  5. You're in. You'll see your API key once (keep it if you need it), and get a welcome email.

There's no tie-in: it's pay as you go, at 10p a name, and you can cancel at any time.

Sign in, and install the app

  1. Go to Sign in, enter your work email and choose Email me a code.

  2. We email you a six-digit code and a link. Either works once, within 15 minutes.

  3. Type the code and choose Sign in, or click the link in the email instead.

  4. You stay signed in on that device for 30 days, as long as you use it.

  5. To install it as an app: on a computer, choose Install app at the top of the page (Edge and Chrome). On an iPhone, open the site in Safari, tap Share, then Add to Home Screen. On Android, choose Install app from the browser's menu.

There are no passwords. If you lose a device, sign it out from Account, under Your devices.

Screen someone

For a customer on the phone, a new proposal, or a contract being drawn up. Everything you add is screened together, as one check with one record.

  1. Choose Screen and add your reference if you have one. Under Add a company, start typing its name or number and pick it from the list.

  2. Its directors and the people who control it appear straight away, and are screened with it. Tick the box below to check each director against the disqualified register too (10p a director).

  3. Add people: their full name as on their ID, their date of birth if you have it (02/01/1968, or just 1968), and who they are. Choose Add this person for each.

  4. The total shows how many names will be screened and what it costs. Choose Screen everyone.

  5. The result appears in a moment: each name, its result, and the nearest listed name. What the results mean.

A date of birth makes all the difference with common names: it rules out listed people born in a different year.

Read the result

Each name gets one of three results, and the check as a whole takes the most serious of them.

ResultWhat it meansWhat to do
clearNothing on the lists resembles them closely.Carry on.
reviewSomeone on a list resembles them, but not closely enough to say it's them. Also shown when a company has a controller whose details Companies House withholds, or a director disqualified under sanctions rules.Compare what you know (date of birth, nationality, address) with the listed person shown. Most reviews are someone else with a similar name. Record what you decided and why, as your firm's procedure says.
matchThey closely match someone on a sanctions list.Stop, and don't proceed. Refer it to whoever handles compliance in your firm, straight away. If it is them, your firm may have to freeze funds and report to OFSI.

Under each name you'll see the listed entries that resemble it, which list they're on, the sanctions regime, and a score. A score of 1 is an exact match.

Decide on a review

When a name resembles someone listed, look at the listed person shown and record whether it's them. The decision is remembered: next time you screen the same person, a listed entry you decided "not them" doesn't raise a review again, so they come back clear, showing who decided and why. Only the account's owner, and people the owner has made reviewers (on Account, under People), can record one.

  1. Open the screening's record: choose Printable record after screening, or find it under Recent, Needs a decision.
  2. Under Decisions, for each listed entry they resembled, compare what you know (date of birth, nationality, address) with the entry.
  3. Write why, then choose Not them or It's them. "It's them" keeps it a match in every screening of them; refer it to whoever handles compliance.
  4. Changed your mind, or recorded it against the wrong entry? Choose Withdraw the decision. Nothing is ever deleted: the record shows every decision, in order.

If the listed entry changes later (a new alias or date of birth), it's looked at again, with your earlier decision shown.

Print or save the record

  1. After screening, choose Printable record (earlier checks are under Recent). Print it, or choose Save as PDF in the print window, and keep it with the customer's file.

  2. Its verification code and QR code let anyone you give it to check at Verify that it came from us and hasn't been changed.

Each record carries a verification code, like K7QM-3XRA-PW9D, and a QR code. Anyone you give it to (an insurer, an auditor) can check at Verify that it came from us and hasn't been changed.

Screen a file

For a book of renewals, a list of new customers, or a whole portfolio: up to 5,000 rows at once.

  1. Choose Files, and drag your spreadsheet onto the page, or choose it. A CSV or Excel file, in any layout.

  2. A window shows your first rows and what each column was taken to be. Change any that's wrong, or set it to Not used.

  3. Under the columns: how many rows will be screened, which have a note, which won't be screened and why, and the cost. Then choose Screen them.

  4. It runs on its own: you can close the window, and we email you when it's done.

  5. Download the results from the same page: your own file, row for row, with each screening's answer added.

Starting from scratch? Download a template with the headings we read without asking.

Keep the results file exactly as you downloaded it. It's signed, so it can be checked at Verify, but opening it in Excel and saving it changes the file, even if you edit nothing. Each row's own verification code can still be checked, one at a time.

Check a record you're sent

  1. Go to Verify (no account needed) and type the code from the record, or scan its QR code.

  2. For a results file, drag the file onto the page: it's checked on your computer, and never sent to us.

  3. Genuine and unaltered means we made it and it hasn't changed. No names are shown: compare what it says with the record you hold.

Prove your record is whole

Each record shows it's genuine. A statement shows more: that your record is whole, with nothing missing. Every screening you make is numbered in order, and each one's signature takes in the fingerprint of the one before, so a record can't be removed or changed without breaking every one after it.

  1. On the 1st of each month, the account's owner is emailed that last month's statement is ready. It's on Statements.
  2. For an audit or a client, make one for any dates you need on the same page.
  3. Download it and keep it with your compliance files. It lists every screening with its number, its verification code and its fingerprint.
  4. Anyone can check it at Verify, by its code or by dropping the file: Genuine, and the record is whole means we signed it, and every record it covers is still held, in order, unchanged.

Because you hold the statements, we couldn't later show you a different history without contradicting them.

Add or remove staff

The person who signed up is the account's owner, and only the owner can do this.

  1. On Account, under People, enter their name and work email and choose Add them. We email them to say they can sign in.

  2. To remove someone, choose Remove beside them. They're signed out everywhere within a minute.

Every screening records who ran it, so each person needs their own sign-in: please don't share one.

Give your developer a key

For connecting your own systems (your CRM, your quote system, Access) to screen automatically.

  1. On Account, under Send a key to your developer, enter their name and email. They get a link, good once within 72 hours, that makes a key for them.

  2. Or choose Issue another key to make one yourself. It's shown once, so copy it somewhere safe.

  3. If a key might have been seen by someone it shouldn't have, Revoke it at once. It stops working within a minute.

Point your developer at the API docs: they have examples for .NET, Access and Excel (VBA), Python, PowerShell and more.

Trial, billing and cancelling

  • The trial lasts 14 days and includes 500 checks. If you use them all, screening pauses until the trial ends and billing starts.
  • The price is 10p for each name screened, including a company's directors and controllers, and 10p for each director checked against the disqualified register. VAT is added.
  • Free: looking companies up, searches, a company check that couldn't tell which company you meant, opening records, and checking records at Verify. Anything that fails isn't charged.
  • Your usage this month and in the trial is on Account.
  • Invoices, your card, and cancelling: on Account, choose Card, invoices and cancelling. It opens Stripe's secure billing page. You're billed monthly for what you used.

Questions

Which sanctions lists do you check?

The UK Sanctions List (published by the FCDO), the EU's consolidated list of financial sanctions (published by the European Commission), the UN Security Council Consolidated List, and Canada's Consolidated Autonomous Sanctions List. We fetch each one every day. If any list is more than two days old, we stop screening rather than screen against an out-of-date list, and you'll see "not screened".

Do you check the EU and US (OFAC) lists?

The EU's, yes, with the UK's. A UK firm's legal duty is to the UK list; the EU's matters if you have operations or customers in the EU. The US (OFAC) list isn't checked at the moment: if you need it, tell us.

Does "clear" mean they're safe to deal with?

It means no one on the lists closely resembles them, on the day you checked. It's a tool to help you meet your obligations, not a decision for you: your own checks, judgement and procedures still apply.

Why did someone with a common name come up as review?

We look for names that are alike, not only identical, because names are spelled and transliterated in many ways. A common name will sometimes resemble someone listed. Adding a date of birth usually settles it: listed people born in a different year are ruled out. If it's still a review, compare the details shown with what you know of your customer.

Why are a company's directors screened too?

Sanctions apply to companies owned or controlled by listed people, not only to the people themselves. So when you screen a company we also screen its current directors and its persons with significant control (its owners), as Companies House lists them.

What is a "withheld" controller?

Companies House sometimes keeps the details of a company's controller private, usually to protect them. We can't screen someone we can't name, so the check is marked review: someone controls the company who couldn't be checked.

What is the disqualified directors register?

Companies House's list of people barred from being company directors. It's optional, at 10p a director. A director disqualified under sanctions rules makes the check a review, whatever the sanctions lists say.

How long do you keep records?

Six years from the date of the screening, then we delete them. For those six years they're held in locked storage: no one can change or delete them, including us. Your own duty to keep records may run longer, for example five years from the end of a customer relationship, so keep your own copy (the printed record or the results file) with the customer's file.

How can we prove to an auditor we haven't left anything out?

With your statements. Every screening is numbered with no gaps, each signature takes in the one before, and a statement proves a whole stretch of them, signed. An auditor can check it themselves at Verify. See Prove your record is whole.

Can a record be changed or deleted?

No. That's what makes it worth something to an auditor. If a screening was wrong (the wrong date of birth, say), screen again: both records are kept.

My results file says it doesn't check out. Why?

Almost always because it was opened and saved again, in Excel or anything else. Saving rewrites the file even if nothing was edited. Download it again from Files, and keep that copy as it is. Each row's verification code still checks out on its own at Verify.

What happens if the service can't screen?

You'll see "not screened" and why: a list that's out of date, Companies House not answering, or our own storage being unavailable. Nothing is charged. Please try again in a few minutes. We never call someone clear when we couldn't check them.

What about data protection?

You send us the names and dates of birth to screen, and we use them only to screen and keep the record for you. You need a lawful basis for doing so, as you would for any check. Our privacy notice says what we hold, why and for how long.

Can we screen automatically from our own system?

Yes. Give your developer a key, and send them to the API docs. It works from anything that can make a web request, including Microsoft Access and Excel.

Still stuck?

Email us at [support address: confirm] with what you were doing and, if it's about a screening, its verification code. Please don't email us names or dates of birth.

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