How to read a sanctions list entry — anatomy of an entry, field by field

Your system or a member of staff has just returned a potential hit — a client’s name similar to an entry on the EU sanctions list. What now? Before you make any decision, you need to be able to read that entry. A sanctions list entry is not a simple note with a name — it is a set of fields containing identification data, a legal basis, and a statement of reasons, which together determine whether you are dealing with a genuine hit or a false alarm.

Legal status as of: 2026-05-20.

TL;DR — key facts in 60 seconds

• A sanctions list entry consists of many fields — the name alone is not enough to confirm or rule out a hit.
• The key fields are: aliases and transliterations (a.k.a.), date and place of birth, identity document numbers, address, position, legal basis for listing, and reason for listing.
• Transliteration of Cyrillic script is the most common pitfall — the same individual may appear under several different spelling variants simultaneously.
• Hard identifiers (passport number, national ID equivalent, tax number) are the key to reliably confirming or ruling out a hit.
• Different lists (EU, MSWiA, OFAC) have different entry structures — what you are looking for in one may be recorded differently, or may not exist at all, in another. See the guide to EU, UN, OFAC and MSWiA sanctions lists for a full overview.
• The outcome of a verification is always one of three states: MATCH, POSSIBLE, or CLEAR — each requires a different course of action.

Why you need to know how to read an entry

A counterparty sanctions check ends the moment your system or a member of staff returns a preliminary hit. That is precisely the point at which theoretical knowledge of the procedure must turn into the practical ability to analyse data. EU regulations — including Council Regulation (EU) No 269/2014 of 17 March 2014¹ — are directly applicable to every company operating in the EU without exception.² This means that a misinterpretation of an entry in either direction generates risk: a false positive blocks a legitimate transaction, whilst missing a genuine hit (false negative) can result in an administrative fine of up to PLN 20 million imposed by the Head of the National Revenue Administration (KAS — Krajowa Administracja Skarbowa) (Article 6(2) of the Act of 13 April 2022).³

The ability to read an entry is also required in order to document a verification correctly. The supervisory authority — the Head of KAS⁴ — will, in the event of an inspection, check which identifiers you used for comparison and why you reached the conclusion you did. Without knowing the structure of an entry, you cannot justify that conclusion.

Anatomy of an entry — field by field

A typical sanctions list entry (using the EU Consolidated List maintained by DG FISMA as an example)⁵ contains the following fields. Below I discuss each of them and explain what it means for your verification.

Name

This is the first field you see. For natural persons it contains the name in the version considered canonical by the authority that made the listing. For legal entities it is the full company name — in the original language or in transliteration, depending on the list. This field alone rarely suffices to confirm or rule out a hit — it is an entry point, not a final answer.

Aliases and former names (Aliases / a.k.a.)

This is the section you must read in full, even if the canonical name does not match. Aliases are all other known versions of a name: pseudonyms, abbreviations, versions transliterated from Cyrillic or other scripts, former names after a change, or the company name prior to a restructuring. A single entry may have several, a dozen, or in complex cases even dozens of aliases. I discuss this topic in detail in the “Aliases and transliterations” section below.

Date and place of birth

For natural persons, this is the first strong identification field. If the date of birth does not match, you have a strong basis for classifying the hit as POSSIBLE (requiring further verification) or CLEAR. Note: the place of birth may be given in the original language, it may be transliterated, or it may use historical place names (e.g. Lwów / Lviv / Lemberg). Do not dismiss a hit simply because the place name looks different from what you expected.

Nationality

An auxiliary field — useful in verification but not conclusive. Many individuals on sanctions lists hold multiple nationalities, or a nationality different from their country of residence or birth.

Identity documents

This is the strongest field for verifying identity. It includes passport number, national identity card number, and national identification number (the equivalent of Poland’s PESEL or NIP in the relevant country). If your counterparty’s document number matches the number in the entry — you have a MATCH. If the number clearly differs and you are confident in the authenticity of your counterparty’s document — you can move towards a CLEAR, but you must justify this in the hit register.

Address

The residential or registered address of the entity. Use it as an additional identifier, not as a primary criterion — addresses change, and those recorded may be historical locations from years ago. A discrepancy in address does not rule out a hit.

Position / Relationship

A field describing the role of the individual or the entity’s connections to other entities and persons. For your verification it has two uses: first, it helps confirm identity if your counterparty holds the same position. Second, it points to a network of connections — and this matters, because EU sanctions cover entities in which a listed person holds more than 50% of the ownership rights or exercises control.⁶ In other words, the position of a listed person may indicate which other related entities you should also check.

Legal basis

This is the number of the regulation or decision on the basis of which the entity was listed. Example: a listing on the basis of Council Regulation (EU) No 269/2014¹ means the entity is subject to restrictive measures in connection with actions undermining Ukraine’s territorial integrity. A listing on the basis of Council Regulation (EU) No 765/2006⁷ means measures relating to Belarus. This field tells you which sanctions regime applies to this particular entity — and therefore what prohibitions that listing places on your company.

Listing date

The date on which the entity was placed on the list. For your verification it has procedural significance: if you verified your counterparty before this date and the result was CLEAR, and the listing date is now after your last verification — you have a new situation that requires action. This is one reason why verification cannot be a one-off exercise.

Statement of reasons

A narrative description of the justification for the listing — why this particular entity was placed on the list. It may contain information about the entity’s role in a power structure, political connections, or involvement in specific sanctioned activities. For your verification this is an auxiliary field: if your counterparty’s business profile bears no resemblance whatsoever to the description in the statement of reasons — you have an additional argument when justifying a CLEAR or POSSIBLE finding. However, this field alone does not substitute for comparing hard identifiers.

Aliases and transliterations — the most common pitfall

Transliteration of Cyrillic script into the Latin alphabet is the greatest source of false negatives in manual sanctions screening. There is no single universal transliteration standard — depending on the system used (ISO 9, BGN/PCGN, GOST, or common transliteration), the same Russian surname may take several different forms in the Latin alphabet.

Examples that illustrate the problem:

• The surname “Иванов” may be transliterated as: Ivanov, Iwanow, Ivanoff, Ivanow — all of which may appear as aliases for the same person.
• The first name “Юрий” will appear as: Yuri, Yuriy, Iuri, Jurij — depending on the system.
• A company name containing “Газпром” becomes in transcription: Gazprom, Gasprom — less common, but it does occur.

What this means in practice: if you search for “Ivanov” and find no hit, that does not mean there is none — also check “Iwanow”. If you are using manual database searching, use partial search (e.g. “Ivan*” or “Iwan*”) and verify all results. The EU Sanctions Map⁸ available at sanctionsmap.eu handles some variants automatically. The EU Financial Sanctions Database (FSD) maintained by DG FISMA⁵ at webgate.ec.europa.eu/fsd/fsf allows searching by aliases.

An analogous problem applies to Arabic, Chinese, and Farsi — the transliteration of these languages into the Latin alphabet is even less standardised than Cyrillic.

Practical rule: if a name is “almost” the same as your counterparty’s but not identical — do not classify it as CLEAR immediately. Check all aliases in full, compare hard identifiers, and justify your decision in the register.

Identifiers — the key to confirming or ruling out a hit

The hierarchy of identifiers in sanctions verification is as follows:

When conducting a manual verification, start with the highest-weight identifiers. If the passport number or national ID equivalent clearly differs, and you are confident in the authenticity of your counterparty’s document — you have a strong basis for CLEAR. If the data matches, or you cannot compare it (because the counterparty has not provided documents) — you are in POSSIBLE territory and need further analysis.

Bear in mind: the absence of an identifier in a list entry is not the same as a discrepancy. Many entries do not contain passport numbers — because the authorities did not have that information at the time of listing. In such cases you compare what you have.

Legal basis and reason for listing — what this means for you

The “legal basis” field in an entry tells you two things: first, which sanctions regime and which prohibitions apply to this entity. Second, which authority made the listing.

Practical examples:

• Listing on the basis of Council Regulation (EU) No 269/2014¹ → entity subject to restrictive measures in connection with actions undermining Ukraine’s territorial integrity. Prohibitions include asset freezing and the prohibition on making funds available.
• Listing on the basis of Council Regulation (EU) No 833/2014⁹ → entity subject to sectoral prohibitions in connection with Russia. The scope of prohibitions is broader and sector-specific — it may relate to specific goods or services.
• Listing on the basis of Council Regulation (EU) No 765/2006⁷ → restrictive measures relating to Belarus.

The “statement of reasons” field contains a narrative justification. It is worth reading because it may contain information about the entity’s network of connections — for example, “person exercising control over entity X” or “beneficiary of a network of companies linked to entity Y”. This directly indicates which other entities you should check through the lens of the over-50% ownership rule.⁶

What this means for your company: the legal basis determines what specific actions are prohibited. A listing does not always mean an absolute prohibition on all contact — some sanctions regimes contain exceptions and the possibility of obtaining a licence from the competent authority. However, assessing those exceptions requires legal advice — do not attempt this on your own.

How to compare an entry with your counterparty’s data — step by step

You have a list entry and your counterparty’s data in front of you. Here is the comparison procedure:

1. Compare all name variants. Check the name in the entry — including all aliases. If your counterparty’s name does not match any of them but is similar, do not jump to CLEAR. Check the identifiers.

2. Compare the date of birth (for natural persons). If the date matches to the day — you have a strong basis for further verification. If it differs — note the discrepancy, but do not end the analysis. Errors in entries do occur.

3. Compare document numbers. This is the critical step. Have you collected a passport number or other hard identifier from your counterparty? Compare it with the “identity documents” field in the entry. A match = indication of MATCH; a clear discrepancy when you are confident in the document’s authenticity = strong basis for CLEAR.

4. Check nationality and country. As an auxiliary factor — not conclusive, but it strengthens or weakens the hit.

5. Read the statement of reasons. Does the entity’s profile in the statement of reasons match what you know about your counterparty?

6. Assess the ownership structure. Check whether your counterparty is an entity in which a listed person or entity holds more than 50% of the ownership rights.⁶ This requires verification in the KRS (National Court Register), CRBR (Central Register of Beneficial Owners), or the relevant foreign register — beyond the sanctions list itself.

7. Assign a result: MATCH, POSSIBLE, or CLEAR.

8. Document every step in the hit register — which identifiers you compared, what discrepancies you found, what decision you reached and why. This is your evidence of due diligence in the event of an inspection by the Head of KAS.⁴

With a MATCH result — freeze the transaction and promptly report the fact to the competent authority (the Head of KAS or MSWiA — Ministerstwo Spraw Wewnętrznych i Administracji, the Ministry of the Interior and Administration — depending on the context). Do not inform the counterparty of the verification result. With a POSSIBLE result — gather additional documents and, if in doubt, seek legal advice.

Differences in entry structure across the EU, MSWiA, and OFAC lists

Not all sanctions lists look the same. Before you begin comparing data, it is worth knowing what to expect from each of them.

EU Consolidated List (FSD)

Maintained by DG FISMA (Directorate-General for Financial Stability, Financial Services and Capital Markets Union) of the European Commission,¹⁰ available in XML and JSON format at webgate.ec.europa.eu/fsd/fsf.⁵ Entries are very detailed: they include many aliases, detailed identification fields, links to statements of reasons in the Official Journal of the EU, the listing date, and the relevant regulation. EU lists have a standardised structure — fields are fixed and described in the XML schema. This is the best-structured list of the three. An interactive view is offered by the EU Sanctions Map⁸ at sanctionsmap.eu.

Polish MSWiA sanctions list

Maintained by the Minister of the Interior and Administration (MSWiA) under the Act of 13 April 2022 (Journal of Laws 2022, item 835),¹¹ available in XLSX and PDF format at gov.pl/web/mswia/lista-osob-i-podmiotow-objetych-sankcjami.¹² The structure is simpler than the EU list — fewer fields, fewer aliases, shorter statements of reasons. For natural persons you will typically find: name, date of birth, nationality, and identity document number where available. For entities: name, country of registration, and identification number where known. The list is updated by ministerial decision — its personal scope may differ from the EU list. A detailed verification procedure for the MSWiA list is covered in a separate article: MSWiA sanctions list — how to check a counterparty.

OFAC SDN List (USA)

Maintained by the Office of Foreign Assets Control (OFAC), U.S. Department of the Treasury,¹³ available in several formats (XML, CSV, PDF) at ofac.treasury.gov.¹³ The structure is similar to the EU list — detailed identification fields, aliases, addresses. An important difference: OFAC entries often contain an additional “Programs” field indicating which sanctions regime the entry belongs to (e.g. RUSSIA-EO14024, UKRAINE-EO13685). This makes it easier to assess what prohibitions apply to a given entity. Note: the OFAC list is US law, not EU law — it applies to Polish companies indirectly, when a transaction has a US nexus (settlement in US dollars, US persons in the structure, export of US-origin goods).¹³

Summary of differences

FAQ — frequently asked questions

Is it sufficient to check only the name to determine a CLEAR result?

No. The name is the entry point for verification, not its outcome. The same combination of first name and surname as in a sanctions entry may apply to thousands of individuals. To confirm or rule out a hit you need to compare hard identifiers — date of birth, document number, or national identification number.

What should I do if the list entry does not contain identity document numbers?

You compare what is available — date of birth, place of birth, nationality, address. If several fields simultaneously point to a discrepancy, you have a strong basis for CLEAR with good documentation. If the fields match or the lack of data prevents you from ruling out a hit — treat the result as POSSIBLE and collect additional identity documents from the counterparty. More on how to distinguish a genuine hit from a false positive in sanctions screening is covered in a separate article.

Do I need to read the statement of reasons for every entry?

You do not need to read it in full for every search, but you should do so when you have a preliminary hit. The statement of reasons contains information about connections that may point to other related entities you should check (the 50% ownership rule).⁶

How do I handle entries in Arabic or Chinese script?

Many lists contain entries both in the original script (Arabic, Chinese, Russian) and in transliteration. If you are uncertain about transliteration, compare hard identifiers — passport number and date of birth are independent of the writing system.

What does “Programs” mean in an OFAC entry?

It is the name of the sanctions regime to which a given entry belongs. For example, “RUSSIA-EO14024” denotes measures imposed under the executive order concerning Russia. This field helps you assess what specific transactional prohibitions apply and whether your company has any connection to that particular regime.

Does the MSWiA list contain the same entities as the EU list?

No, they are two separate lists. The MSWiA list may contain entities not on the EU list and vice versa. You must check both — neither substitutes for the other. A detailed discussion of the differences between the lists is provided in the article what is a sanctions list and which lists apply to Polish companies.

How Sanqto can help

Manual analysis of an entry — with all its aliases, transliterations, and the comparison of several identification fields — is time-consuming and error-prone, particularly when you are verifying dozens or hundreds of counterparties each month. Sanqto automates this process: the software operates on-premise (your counterparty data never leaves your company’s infrastructure), retrieves current versions of the lists from DG FISMA,¹⁰ MSWiA,¹² and OFAC,¹³ handles transliterations and aliases natively, and returns a result in three states — MATCH, POSSIBLE, or CLEAR — with a complete audit trail ready to present on request to the Head of KAS.⁴ More about sanctions screening for your industry: travel agencies and tourism, real estate. A full overview of the verification process is available in the article counterparty sanctions verification — step by step.

Legal basis

• Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine — CELEX 32014R0269
• Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine — CELEX 32014R0833
• Council Regulation (EU) No 765/2006 of 18 May 2006 concerning restrictive measures in respect of Belarus — CELEX 32006R0765
• Directive (EU) 2024/1226 of the European Parliament and of the Council of 24 April 2024 on the definition of criminal offences and penalties for the violation of Union restrictive measures — CELEX 32024L1226
• Act of 13 April 2022 on special solutions for countering support for aggression against Ukraine and for the protection of national security (Journal of Laws 2022, item 835) — ISAP
• EU Financial Sanctions Database (FSD) — DG FISMA — webgate.ec.europa.eu/fsd/fsf
• EU Sanctions Map — sanctionsmap.eu
• Polish MSWiA sanctions list — gov.pl/web/mswia
• OFAC Specially Designated Nationals List (SDN) — ofac.treasury.gov

Footnotes

Information, not legal advice. This article is intended for informational and educational purposes only. It does not constitute legal advice. Legal status as of: 20 May 2026. Your company’s specific obligations depend on its business profile and require individual assessment — if in doubt, consult a lawyer or compliance adviser.