Sanctions lists – a hot topic
The issue of sanctions lists is omnipresent for business operators at the moment. One reason for this is the constantly rising severity of penalties and restrictions. We are forever hearing about sanctioned operators, grounded aircraft, heavy fines and even the threat of prison sentences.
On the other hand, the Ukraine War has also set new benchmarks. Since Russian troops marched into Ukraine during the night of 24 February 2022, the West, and both the European Union and Switzerland in particular, as well as the G7 Nations, have imposed numerous sanctions on Russia and Belarus.
In order to avoid restrictions as an operator, it is important to regularly review sanctions lists in the case of both new and existing clients. Besides checking passengers, it is also necessary to check crews, companies and aircraft.
Not optional
Global sanctions are an important foreign policy instrument with which governments pursue political and diplomatic objectives as well as respond to human rights violations. New regulations, with strict and often complex requirements, are frequently being imposed in the course of implementing global sanction packages.
Collaborations with sanctioned entities can lead to far-reaching consequences under criminal law, which is why it is essential to carry out checks.
The safest option is essentially to check every entity before every trip since sanctions lists are constantly being extended and updated. This is the only reliable way of ensuring comprehensive checks and minimizing risks. This is equally recommended in the case of new business relationships and on-boarding due diligence as well as long-standing business partners, and on-going due diligence. If an individual or an entity is on a sanctions or an anti-terror list, it is not permitted to carry these individuals or enter into any business relationships with them. Heavy restrictions can apply if this is overlooked.
Not a trivial offense
Non-compliance with global sanctions can lead to serious penalties. Depending on the legislative environment, these can be fines or even prison sentences of several years. Penalties are mainly aimed at the general managers of the companies in question. Non-compliance can also lead to massive commercial and financial risks for companies, meaning that checking sanctions also needs to be regarded as part of risk management.
Restrictions are based on the various legal bases of the relevant region, with the nationality of the entity, the country of origin and the country of destination playing a role as well as those of any airspace transited. In some parts of the world it is even required to contact the authorities if you are contacted by individuals subject to sanctions.
Europe, USA & worldwide
One of the biggest problems for operators when it comes to checking sanctions lists is the scale of the challenge. There are numerous different lists of sanctioned individuals and companies worldwide and they all contain tens of thousands of entries. What’s more, these lists are constantly being updated, added to and some entities removed.
Basis: UN sanctions list
The UN sanctions list serves as the basis for sanctions lists issued at the European and national levels. All member states of the UN are obligated to report individuals on this list. There are also European (EU) sanctions lists. These incorporate entries on the UN sanctions list. Several states also maintain their own registers on the basis of international sanctions lists. For example, the UK, USA and Canada maintain comprehensive sanctions lists. In order to develop a concept for regularly checking sanctions lists, the first step is to find out which sanctions lists are relevant.
EU sanctions lists
If a company has its head office and operations mainly based in the EU, it is at least necessary to check the EU sanctions lists. At the EU level, a differentiation is made between sanctions lists related to individuals and specific countries. For example, the CFSP list (Consolidated list of persons, groups and entities subject to EU financial sanctions) contains the names of all individuals, companies and organizations which have been sanctioned by the EU irrespective of their nationality. On the other hand, the European Iran Embargo for example focuses on sanctions imposed on Iranian nationals and companies.
British sanctions list
The Consolidated list of Financial Sanctions Targets in the UK acts as a centralized sanctions list for the UK and contains both sanctions imposed by the EU as well as additional entries at the national level.
US sanctions list
The OFAC sanctions list contains information about the specific sanction targets of the United States. The OFAC sanctions generally apply to all individuals and entities which could represent a threat to the national security, foreign policy or economy of the United States.
Other sanctions lists
Besides the sanctions lists of the UN, EU, UK and USA, there also exist numerous other lists for various regions as well as lists issued by security organizations such as the ‘FBI Most Wanted’ directory or the ‘Red Notice List’ issued by Interpol. What is critical here is whether the relevant focus applies to a company or not.
Automated checks
As an operator, you face the challenge of carefully reviewing all relevant sanctions lists without neglecting your core business. Manual checks are time-intensive and tedious due to the number of sanctions lists. That’s why it makes sense to find an automated solution. Automated sanctions checks protect your company and minimize compliance risks or the risk of being recorded on a compliance list.
The paxfiles.com Sanctions List Scanner API can easily be integrated with any external system to enable users to perform sanctions checks at the click of a button.
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The solution: paxfiles.com
Implementing an automated tool is an important step in the direction of compliance with sanctions lists.
In order to comply with legal requirements, it is essential to have a robust sanctions list checker in place. This software should be able to quickly and accurately search lists of known individuals and entities that are subject to sanctions or other legal restrictions.
paxfiles.com is your means of ensuring that sanctions lists are checked in real time without additional effort, meaning that you are informed about suspect individuals and entities. This ensures that you avoid any legal violations in advance.
The most important sanctions lists of the UN, US, EU, UK, CH, AU, CA, FBI and Interpol are constantly updated and reviewed.
paxfiles.com has been specially developed for the aviation sector and for carrying passengers.
Our API can however be integrated into any and every system.
Frequently Asked Questions
