# Sanctions Screening Beyond OFAC: The EU and UK Lists Your US Check Misses

Source: https://landedgehq.com/blog/2026-11-15-sanctions-screening-eu-uk-lists-beyond-ofac/

Cross-border operations guide · November 15, 2026


**Short answer:** Sanctions screening has to cover more than OFAC. The EU maintains a consolidated list of sanctioned persons and entities, searchable through the EU Sanctions Map. The UK maintains the UK Sanctions List, published by the Foreign, Commonwealth and Development Office, which became the sole UK source when the OFSI Consolidated List closed on January 28, 2026. The UN Security Council maintains its own consolidated list. A counterparty that appears on any of them is a counterparty you cannot ship to, and a US-only screen will not find them.

## OFAC is the floor, not the ceiling

OFAC, the US Treasury's Office of Foreign Assets Control, is the list most American companies screen against, and it is the list most screening tools check first. It is also incomplete as a compliance screen, because it is a US list. The European Union maintains its own consolidated list of persons, groups, and entities subject to EU financial sanctions, searchable through the EU Sanctions Map. The United Kingdom maintains the UK Sanctions List, published by the Foreign, Commonwealth and Development Office. The United Nations Security Council maintains its own consolidated list. A counterparty can appear on any of those lists and not on OFAC, and a shipment to that counterparty is still illegal.

The UK change is the one most screeners have not caught up with. The OFSI Consolidated List, which was the UK's list for years, closed on January 28, 2026, and the UK Sanctions List is now the sole UK source. A screening tool that still checks the OFSI Consolidated List is checking a list that no longer updates, and a counterparty added to the UK list after January 2026 will not appear in it. Check which list your tool queries, and when it last updated.

## The 50 percent rule catches the companies the lists miss

The lists name people and entities. The 50 percent rule catches the companies they own. OFAC's rule is that an entity owned 50 percent or more in the aggregate by one or more blocked persons is itself blocked, even when it is not named on any list. The ownership is counted in aggregate: two blocked persons owning 30 percent and 25 percent block the entity, even though neither owns half alone. The rule applies to subsidiaries, to joint ventures, and to any entity where the blocked ownership adds up to half.

The practical problem is that ownership is not always visible. A counterparty that is clean on every list can be owned by a blocked person through a holding company, a nominee, or a chain of subsidiaries that the screening tool does not follow. The screen has to include a beneficial ownership check, and the check has to follow the chain past the first layer. A screen that checks only the named counterparty is a screen that misses the rule.

## What a complete screen looks like

A complete screen checks the counterparty against OFAC, the EU consolidated list, the UK Sanctions List, and the UN Security Council list, and it checks the beneficial owners against the same lists, applying the 50 percent rule in aggregate. It screens the buyer, the consignee, the notify party, the end user, the banks, the agents, and the vessel, because a sanctioned party can appear in any of those roles. And it re-screens before every renewal, every payment, and every shipment, because the lists change daily and a counterparty that was clean last month can be listed this month.

Document the screen and keep it with the shipment file. The screen is the defense if the shipment is questioned, and the screen has to exist before the shipment, not after it. For the classification that pairs with the screen, [ECCN versus EAR99 and the licence check](https://landedgehq.com/blog/2026-11-13-eccn-vs-ear99-license-check/) covers the classification question, and [OFAC sanctions screening and the 50 percent rule](https://landedgehq.com/blog/2026-11-14-ofac-sanctions-screening/) explains the US list in full.

## Frequently asked questions

### What lists should I screen against besides OFAC?

The EU consolidated list, searchable through the EU Sanctions Map; the UK Sanctions List, published by the Foreign, Commonwealth and Development Office; and the UN Security Council consolidated list. A counterparty can appear on any of them and not on OFAC.

### What happened to the OFSI Consolidated List?

It closed on January 28, 2026. The UK Sanctions List is now the sole UK source. A screening tool that still checks the OFSI list is checking a list that no longer updates.

### What is the OFAC 50 percent rule?

An entity owned 50 percent or more in the aggregate by one or more blocked persons is itself blocked, even when it is not named on any list. Two blocked persons owning 30 and 25 percent block the entity, even though neither owns half alone.

### Who should I screen on a shipment?

The buyer, the consignee, the notify party, the end user, the banks, the agents, and the vessel, plus the beneficial owners of each. A sanctioned party can appear in any of those roles, and the lists change daily, so re-screen before every shipment and payment.