The most expensive sanctions mistakes aren't made by people who ignore the rules — they're made by people who screen a counterparty's name, see nothing, and stop there. The exposure usually sits one level down, in who owns the company you're dealing with.
Not just whether your counterparty is on a list, but whether anyone on a list owns 50% or more of it — directly or through layers — which places the company under the same restrictions even though its own name is clean.
We handle the Russian side — the ownership analysis, ЕГРЮЛ and the judgement calls — and coordinate with your OFAC or EU adviser on their home regimes rather than opining on US or EU law ourselves.
Sanctions screening feels like it should be simple: take the counterparty, run it against the lists, and if nothing comes back, proceed. That instinct is exactly what causes the serious mistakes. A company whose own name appears on no list can still be fully caught by sanctions — because of who owns it. Screening the name is the start of the analysis, not the end of it.
This article is about the methodology rather than any current list, deliberately. Sanctions lists change constantly — additions and removals land within days — so the value is not in knowing today's names but in knowing how to check properly, in a way that survives the next update. The rest of this piece is that method.
The rule that drives most of the risk is ownership-based. A company is treated as blocked — subject to the same restrictions as a listed person — if one or more listed persons own 50% or more of it, whether directly or indirectly through intermediate companies, even though the company itself is not named anywhere. It is a shadow status: no entry on any list, but the restrictions apply in full.
That is why a name-only check is so dangerous. The listed person is not the company you are dealing with; they are somewhere in its ownership. Finding them requires mapping who owns your counterparty, not just reading its name against a database.
A company is blocked if listed persons own 50% or more of it — directly or indirectly — even though its own name appears on no list. Two sanctioned owners at 25% each aggregate to 50%. The exposure is in the ownership, not the name.
Three specific errors account for most of the mistakes, and they are where careful screening earns its keep.
The first is the aggregation trap. Two separate listed persons each owning 25% of a company add up to 50%, so their stakes are aggregated and the company is caught — you cannot treat each as 'below the threshold'. But aggregation works within a single sanctions regime: stakes held under different programmes are not simply added together. The arithmetic that catches a company under one regime may not catch it under another, and assuming otherwise cuts both ways.
The second is the one-level stop. Practitioners check the company directly above the counterparty, find it clean, and conclude the chain is clean. Listed persons hide precisely behind layers of formally unlisted intermediaries. The check has to run to the bottom of the ownership structure — to the ultimate individual owners — not stop at the first tier.
The third is the stale screen. A screen confirms a position on the day it is run and no longer. Ownership changes, and lists change in both directions — companies are added, and others are removed. A company that was clean last year can be owned by a listed person this year, and a check done at onboarding says nothing about the position at the next payment. This is not an argument for screening once carefully; it is an argument for screening repeatedly.
Listed persons hide behind layers of unlisted intermediaries, so checking only the company directly above your counterparty misses them. And a screen is good only for the day it's run — ownership and lists both change. The two traps that catch practitioners most: stopping one level up, and trusting an old check.
A foreign company is usually exposed to more than one sanctions regime at once, and they do not mirror each other. The US, EU and UK regimes differ on the ownership threshold, on whether control (as opposed to ownership) is a separate trigger, and on how they treat aggregation. 'We checked under one regime' is not the same as 'we are clear everywhere'.
This is also where we are careful about our own role. We handle the Russian side of the analysis — the ownership structure, the Russian corporate records, and the judgement about what a Russian company's real ownership is. On how your home regime applies — whether a position is permissible under US or EU law — we coordinate with your OFAC or EU counsel rather than opining on their law ourselves. The two pieces fit together: the Russian-side facts we establish are what your sanctions counsel needs to reach their conclusion.
We establish the Russian ownership picture — ЕГРЮЛ shows direct participants but not indirect owners or nominees — and coordinate with your OFAC or EU counsel on their regimes. The Russian-side facts we build are what your sanctions adviser needs to conclude.
Much of what screening involves — running names, mapping percentages — can be automated, and software does it well. The reason to involve advisers rather than a database is the part that cannot be automated: judgement on the facts that don't resolve cleanly.
That is where the real questions live. A structure can look alarming on paper and be genuinely clean once the ownership is properly understood — an intermediate holding that screens as a hit but resolves on inspection. The reverse is also true: a structure that passes an automated check can be one a cautious adviser would still not touch, because the ownership is opaque or the counterparty won't disclose its ultimate owners. 'Formally permissible but we would not advise it' is a conclusion a database cannot reach. Establishing the Russian ownership picture accurately, and forming a view on the genuinely ambiguous cases, is the work.
Russia adds a specific difficulty to all of this. The public corporate register (ЕГРЮЛ) shows the direct participants in a company, but it does not reliably show indirect ownership through chains, ultimate beneficial owners behind intermediaries, or nominee arrangements. So the register is the entry point to the ownership question, not the answer to it.
Bridging that gap — from what ЕГРЮЛ shows to who actually owns and controls a Russian counterparty at the 50% level — is exactly the Russian-side analysis a foreign group cannot easily do from abroad and an automated tool cannot finish. It is where careful, informed work turns a name that screened clean into a position you can actually rely on, or a warning you needed.
Not necessarily. A company whose own name is clean can still be fully caught if listed persons own 50% or more of it, directly or through intermediate companies. That ownership rarely shows on the counterparty's own record, so a name-only check misses exactly the exposure that matters. The real test is who owns the company, mapped to the bottom of the structure.
Within a single sanctions regime, yes — two listed persons each owning 25% aggregate to 50% and the company is caught, so you can't treat each as below the threshold. But stakes held under different regimes aren't simply added, and the three main regimes (US, EU, UK) don't align on threshold, control or aggregation. That's why a check under one regime isn't clearance everywhere.
A screen is only good for the day it's run. Ownership changes, and lists change in both directions. A company clean at onboarding can be owned by a listed person by the time of your next payment — so a one-off check says little about the current position. This is the practical reason regular re-screening, rather than a single check, is worth doing.
We handle the Russian side — establishing who really owns and controls a Russian counterparty, which is where the exposure usually hides and which is hard to do from abroad. On whether a position is permissible under US or EU law, we coordinate with your OFAC or EU counsel rather than opining on their law ourselves. The Russian-side facts we establish are what your sanctions adviser needs to reach a conclusion.
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