WorkflowThird-Party Risk Management

Supplier Sanctions Screening

Supplier sanctions screening that finds the supplier blocked through its owners, and stops the payment before the run

No payment reaches a supplier blocked through its owners; every alert brings its evidence.

See one case, screen by screen ↓
demo14minto rescreen 18,412 suppliers and 46,930 owners and officers after 226 new list entries
demo55%blocked ownership found on a supplier that is on no list — 30% + 25%, recomputed by a second agent
demo94%of September's 1,204 alerts arrived with a proposed decision and its evidence
target0paymentsto suppliers blocked through their owners
In short

What is Supplier Sanctions Screening?

Supplier Sanctions Screening checks every supplier and every owner behind it against the OFAC, BIS, EU, UK and UN lists on each list change, and applies the 50% ownership rules. Seven agents watch the lists, trace owners from registry documents, check each other's arithmetic and hold exposed payments before the run; the sanctions compliance officer confirms or clears each case with a reason and a signature.

How to choose AI solutions for back-office and enterprise work →

Updated

The problem

Why a supplier on no list still gets paid

Name screening checks the supplier's name against the lists. But under OFAC's 50 Percent Rule a company owned 50% or more, directly or indirectly and in aggregate, by blocked persons is itself blocked, and OFAC does not publish who those companies are. A supplier owned 30% by a listed company and 25% by a holding of a newly listed person passes every name check, and is blocked. The ownership lives in company registries, filings and the supplier's own declaration, often in another language, and it is usually checked once, at onboarding.

Meanwhile the alert queue is full of near-namesakes, so analysts stop reading the reasons and real hits wait behind false positives. The US, EU and UK tests give different answers for the same stakes. Accounts payable learns of a block after the payment run, and each payment is its own strict-liability violation. When OFAC asks why a payment was made or a match was cleared, the answer is spread across emails, screenshots and one analyst's memory.

typical$377,700or 2×the payment: the IEEPA civil maximum, per violation
typical85–95%of name-screening alerts that are false positives
typical10business daysto report blocked property to OFAC, from the day it is blocked
Where the hours after a list change goestimated
By hand36 days
With the solution4.3 days
  • Rescreening suppliers, owners and officers against the change6 → 0.3 d
  • Clearing near-namesakes and false positives8 → 1.5 d
  • Tracing owners in registries and doing the 50% arithmetic10 → 1 d
  • Working out the US, EU and UK answer for each paying entity3 → 0.3 d
  • Finding and stopping exposed invoices before the payment run3 → 0.3 d
  • Case memo, the OFAC report and the evidence file6 → 1 d

Estimated hours of compliance, procurement and accounts payable time for one list change across a large supplier base, by hand and with the solution.

How it works

How a list change moves

Seven agents watch the lists, trace every owner, check each other's arithmetic and hold payments; the sanctions officer decides and signs.

What comes in
Lists and records in7 lists · OFAC, BIS, EU, UK, UN, registries, ERP
Agents at work
List watcherwhat changed
Then
Screening agentsuppliers + owners
Then
Ownership agent50% arithmetic
Ownership verifierrecomputes
Control and evasion agentbeyond 50%
Then
Payment hold agentbefore the run
Report writerOFAC report
A person decides
Sanctions officerconfirms or clears, signs
What comes out
Payments held
Signed decision
OFAC report drafted
One case, step by step

One list change, from the OFAC update to a signed block

Kestrel & Vane Group pays 18,412 active suppliers. At 18:40 ET on 6 October, OFAC publishes an SDN update with 212 new entries. One of them, Rustam Vellin, is the sole owner of a shareholder of Orion Components Ltd, a precision-castings supplier in Limassol that Kestrel & Vane Industrial Inc. pays $2.9M a year. Here is what happens next, screen by screen, in the working solution.

  1. 016 Oct, 18:52

    Everyone rescreened the same evening

    List watcher and Screening agent

    The list watcher reads the OFAC update (212 added, 3 removed) and the UK list change of 11:30 (14 added) and starts a rescreen. The screening agent checks 18,412 suppliers and 46,930 owners and officers, with Cyrillic, Arabic and Chinese transliteration, and rebuilds ownership where an owner matched. Fourteen minutes later there are 9 potential matches, each with a proposed decision.

    List watcher: “OFAC published an SDN update at 18:40 ET: 212 new entries, 3 removed. I started a rescreen of every supplier and every owner.”

  2. 02Wednesday morning

    The briefing is a conversation, not a dashboard

    Daniel Brooks · Sanctions Compliance Officer

    Daniel opens Today: “Overnight the agents rescreened 18,412 suppliers and 46,930 owners against 226 new list entries. 7 things need you; the payment run is tomorrow at 10:00.” Each agent reports one item with its sources and one next step: Orion first, then a UK name match on Petrova Logistics FZE, a control question on Brightwell Alloys, an onboarding request, and the matches the agents propose to clear.

    Ownership agent: “Orion Components Ltd is on no list, but is blocked through its owners: 55% under US rules. A second agent recomputed it and agrees. I paused 3 invoices, $410,000, before tomorrow's run.”

  3. 03Open the case

    The ownership bar crosses the 50% line

    Daniel Brooks · Sanctions Compliance Officer

    Orion's owners are one bar, each segment sized by its stake: Varkon Trading LLC 30%, held through Ardent Nominees Ltd and on the SDN list since 12 Mar 2025; Pellon Invest Ltd 25%, owned 100% by Rustam Vellin; Meridale Capital Partners SA 28% and 14 other holders 17%, with no match. The two listed segments add up to 55%, past the dashed line at 50%. Beside it: $410,000 paused before the 8 Oct run, and an OFAC report due 22 Oct 2026 if he blocks.

    “55% blocked ownership · blocked under US (OFAC) rules”

  4. 04The agents' working

    One agent adds it up; a second checks it blind

    Ownership agent and Ownership verifier

    The screening agent found no name hit on Orion or its two directors (best score 0.41), but Pellon's sole owner matches the new entry on name, date of birth and passport number. The ownership agent reads both registry extracts, resolves the nominee and writes out 30% + 25% = 55% (96% sure). The ownership verifier recomputes from the same documents without reading that answer, and agrees.

    Ownership verifier: “I recomputed from the two registry extracts without reading the first answer: 30% + 25% = 55%. Agrees.”

  5. 05One click on 25%

    Every percentage opens its passage

    Daniel Brooks · Sanctions Compliance Officer

    Clicking the Pellon segment opens the Cyprus companies registry extract for Pellon Invest Ltd, company no. HE 412650, of 19 Aug 2026. The passages the agents used are highlighted: Rustam Vellin as the only shareholder, 1,000 shares or 100%, and as director, with his date of birth and passport number. A side panel shows which agents used the passage and for what: the screening agent, the ownership agent and the verifier.

  6. 06US · EU · UK

    The same stakes, three answers

    Ownership agent and Control and evasion agent

    The ownership map writes out how 55% is reached under each test. US, aggregate 50% or more: Varkon 30% + Pellon 25%, counted in full, so blocked. EU: Vellin is not on the EU list, so 30%, not owned. UK, one person more than 50%: 30%, not owned. The control and evasion agent adds that Orion's own declaration of 3 Feb 2026 names Ardent Nominees for the 30%, not Varkon, and suggests a control review for the EU and UK companies instead of a block.

    The control and evasion agent never blocks on red flags alone; it always asks a person.

  7. 07In plain words

    He asks, then tells the agents what to do

    Daniel Brooks and the Payment hold agent

    Daniel asks “Which payments are exposed?” The payment hold agent answers with the three invoices in Thursday's 10:00 run — INV-77120 $162,400, INV-77188 $131,600, INV-77231 $116,000 — all paused, and an open PO-55810 for $72,800 it has not touched. He types “Hold the open PO too”. The PO is held in the ERP, Marco Ferreira is told, and the total held for Orion is $482,800.

    The payment hold agent pauses; it never releases a payment and never pays.

  8. 08Confirm block

    A reason, a signature and its meaning

    Daniel Brooks · Sanctions Compliance Officer

    He picks the reason “Owned 50% or more by blocked persons (OFAC 50 Percent Rule)”, which is stored with his signature and goes into the evidence pack. The agents then turn the paused invoices into blocks, mark supplier V-104882 as blocked in the supplier master, draft the case memo for Rachel Ames and ask Aiko Tanaka for a control review in the EU and UK companies, due 14 Oct.

    “Signing as Daniel Brooks, Sanctions Compliance Officer · Meaning: I have reviewed the evidence and make this decision.”

  9. 09Same morning

    The OFAC report is drafted, not filed

    Report writer

    The report of blocked property is ready the same morning, due 22 Oct 2026 — 10 business days, Columbus Day excluded. Reporting entity Kestrel & Vane Industrial Inc., Cleveland, Ohio; why blocked, 55% owned by Varkon Trading LLC and Pellon Invest Ltd; property, 3 payables of $410,000 and PO-55810 for $72,800; every field cites its source. Daniel can sign and file it, or ask Rachel to review first.

    “Drafted by the report writer; nothing is filed or sent without a signature.”

  10. 10Before Thursday's run

    AP sees exactly what will not be paid, and why

    Marco Ferreira · Accounts Payable Lead

    Payment holds shows Orion blocked and signed, $482,800 in four items; Petrova's two invoices, $86,200, paused and waiting for a decision; and Brightwell's PO-55642 for $54,900, not held, due in the 22 Oct run while its control review is open. The 8 Oct run, about $64M, goes ahead without the held items. Any release needs a reason and a second approver.

    “The payment hold agent pauses; only people release.”

Who it’s for

Built for everyone between a list change and a payment run.

The same list change, seen by five of the people who carry it — what their week looked like, and what it looks like now.

DB
Daniel BrooksSanctions Compliance Officer · decides every hit and block, signs the OFAC reports
Sanctions Compliance Officer
Before
Gets a name-match alert, a separate ownership lookup and an email from AP — and has to build the case for every decision himself.
Now
Opens a case with the ownership bar, the agents' working, a second agent's check and every source passage, and makes one signed decision.
AT
Aiko TanakaTrade Compliance Analyst · name matches, licences and the export-control lists
Trade Compliance Analyst
Before
“Ninety alerts a day, and eighty-five are the same three names.”
Now
Each match arrives compared field by field with a proposal; she checks a sample and clears the six weaker matches together, with a reason.
MF
Marco FerreiraAccounts Payable Lead · runs the Thursday payment run, about $64M a week
Accounts Payable Lead
Before
“If a payment has to stop, I need to know by Wednesday night.”
Now
Sees every held invoice and PO with its reason before the run, and can be the second approver when someone asks for a release.
HO
Hannah OkoroProcurement Operations Lead · onboards about 60 new suppliers a month
Procurement Operations Lead
Before
“Tell me before I sign them, not after the first PO.”
Now
Gets a screening result before onboarding, including suppliers the suspended BIS Affiliates Rule would restrict if it returns on 10 Nov.
RA
Rachel AmesAssociate General Counsel, Trade & Sanctions · licences and disclosures
Associate General Counsel, Trade & Sanctions
Before
“No disclosure goes out without the memo and the sources.”
Now
Receives the drafted report and case memo with every field cited, and approves licence renewals the report writer prepares.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven agents watch the lists, trace every owner, check each other's arithmetic and hold payments; the sanctions officer decides and signs.

List watcher

Checks seven lists every 15 minutes — OFAC SDN and non-SDN, the BIS Entity List and Military End-User List, the EU consolidated list, the UK and UN lists, and your own do-not-deal list — sees what changed and starts a rescreen of every supplier, owner and officer.

  • Never edits a list
  • Never skips a removal
Screening agent

Matches suppliers, owners and officers on names, aliases and transliteration, address, registry and tax numbers and dates of birth, and explains field by field why each match is or is not a hit.

  • Never clears a match above 0.92 on its own
  • Never decides a true hit
Ownership agent

Builds each supplier's ownership chain from registry extracts, filings and declarations, and computes the direct, indirect and aggregate blocked stake under the US, EU and UK tests.

  • Never assumes a percentage it cannot cite
  • Flags nominees
Ownership verifier

Recomputes every block independently from the source documents and escalates any disagreement to a person with both workings.

  • Never sees the first agent's answer first
  • Never averages a disagreement
Control and evasion agent

Looks beyond 50% for the control and sham-transfer red flags in OFAC's March 2026 guidance: stake cuts near a listing, transfers to relatives, nominees, shared directors and declarations that contradict the registry.

  • Never blocks on red flags alone
  • Always asks a person
Payment hold agent

Finds the open invoices, POs and scheduled payments for an exposed supplier in the ERP and pauses them under rule R-3 before the next payment run, showing what it paused and how to undo it.

  • Never releases a payment and never pays
  • Every hold can be undone by a person
Report writer

Drafts OFAC blocked and reject reports, case memos, supplier notices, licence renewals and the monthly summary, and tracks the 10-business-day clock.

  • Never files or sends
  • A person signs
Sanctions officer

Decides and signs; two people release. The agents propose; a named person decides.

Ask in plain words

Ask about any supplier, owner, payment or list

On Today and inside every case, the agents answer in plain words with their sources — and act when you tell them to.

What has to be decided before the payment run?

Two suppliers, both already paused: Orion Components Ltd, $410,000 (55% blocked ownership under US rules), and Petrova Logistics FZE, $86,200 (UK listing, 0.96). If you decide nothing, both stay paused and the run goes ahead without them.

Why does Pellon count in full?

Because Rustam Vellin owns 100% of Pellon Invest Ltd, Pellon is itself blocked, and OFAC counts a blocked entity's stake in full, not multiplied down. So Pellon's 25% of Orion counts as 25% blocked. Had Vellin owned only 40% of Pellon, Pellon would not be blocked and its stake would not count.

What changes under EU and UK rules?

Under the EU test only Varkon is listed, so the listed share is 30%, below 50%. Under the UK test one designated person must hold more than 50%; Varkon's 30% does not. So Kestrel & Vane's EU and UK companies are not barred by ownership, but the nominee arrangement is a control question.

Who else do we pay that Varkon or Vellin owns?

One other supplier: Castellan Forge Srl (Italy), 8% owned by Varkon Trading LLC. 8% is far below every line and there are no red flags, so it stays clear and on watch. Rustam Vellin owns nothing else we pay.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

TodayThe agents' overnight briefing as a conversation: one message per item, each with its sources and one next step, and questions you can ask.
The case and its ownership barEvery owner a segment sized by its stake, listed owners in red, the 50% line, the US, EU and UK switch, and what is at stake.
The agents' workingEach agent reports what it did, how sure it is and whom it handed to; the ownership verifier recomputes the block on its own.
Ask and instructQuestions and instructions in the same thread: the exposed payments listed, and the open PO held on request.
Ownership mapThe chain from the supplier up to each owner, what counts and what does not, and how 55% is reached under each test.
EvidenceThe registry extract with the passages the agents used highlighted, and which agent used each one for what.
Confirm and signA reason code, an optional note, and the signature with its meaning, stored with the decision and the evidence pack.
Reports and filingsThe OFAC blocked property report drafted with its due date and every field cited, waiting for a signature.
Payment holdsHeld invoices and POs by supplier, why and since when, ahead of the next payment run; release needs two people.
When the readings disagreeA listed owner's stake cut from 51% to 49% nine days before its listing, three red flags, and two documents that give two answers.
ReviewEvery open item with its proposal; the six weaker name matches selected to clear together after a sample check.
List changesThe seven lists watched, last night's rescreen step by step, what it found, and who the suspended BIS rule would catch.
Rules and thresholdsMatch thresholds, the ownership test for each paying entity, the BIS watch and rules R-1 to R-5, each change a new version.
Governance

Built for strict liability: cited, checked twice, signed.

Every percentage cites its passageEach stake, match reason and red flag links to the passage it came from — the registry extract, the list entry, the supplier's declaration, the ERP record or the guidance — and shows which agent used it.
A second agent checks every blockThe ownership verifier recomputes each block from the documents without seeing the first answer. When the two disagree, as on Brightwell Alloys (49% against 51%), the case goes to a person with both workings.
Only people decide, with a reason and a signatureConfirming a block or hit, clearing a match and filing a report need a named person, a reason code and a signature with its meaning. Clearing a match above 0.92 needs a second person.
Payments paused visibly, released by twoThe payment hold agent may pause payments under rule R-3, and shows what it paused and how to undo it. It never releases or makes a payment; a release needs a reason and a second approver.
Suspended rules watched, never enforcedThe paying entity decides which tests apply. For the suspended BIS Affiliates Rule the agents work out who it would catch on 10 Nov 2026, and block no one today.
Every step on the audit trailEvery agent step and every human decision is recorded, and the trail can be filtered by agents or people and by case. A per-case evidence pack holds the sources with their retrieval records, the agents' workings, the verifier's recomputation, every message and the signed decisions, in one file.
Configuration

Your thresholds and tests, not ours

Every threshold, test and rule is a setting. Each change is saved as a new version and logged, and decisions keep the version they were made under.

SettingDefaultChoose from
Propose a clear below this score0.80the agent still shows its evidence; a person confirms
Two people decide above this score0.92clearing a strong match needs a second person
Ownership tests by paying entityUS: OFAC · EU: EU · UK: UKOFAC aggregate 50% or more · EU aggregate 50% or more · UK one person, or persons acting jointly, more than 50%
BIS Affiliates RuleSuspended until 9 Nov 2026 · pre-compute exposure onpre-compute who it would catch, block no one · off
R-1 · Rescreen on every list changeOnsuppliers, owners and officers
R-3 · Pause payments at 50% blocked ownershipOnunder any test that applies to the paying entity · reversible · tells AP and compliance
R-4 · Control review after a stake dropOnwhen a listed owner drops below 50% within 90 days of a listing
ClocksTrue hit within 4 business hoursownership block before the next payment run · control review within 5 business days · OFAC report within 10 business days · licence reminder 30 days before expiry
Connections

Works with the lists and records screening already runs on

Sanctions and export-control listsOFAC, BIS, EU, UK and UN lists and your do-not-deal list, every 15 minutes
ERPsupplier master, open invoices, POs and payment runs; place and lift holds
Procurement suitenew-supplier requests and purchase orders
Company registriesextracts and filings in 42 countries, plus corporate ownership data where registries are closed
Supplier declarationsownership declarations and shareholder registers the supplier sends
Licences and guidanceOFAC and UK licences, the 50 Percent Rule, EU Best Practices, UK ownership and control, the BIS Affiliates Rule
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
0
payments to suppliers blocked through their owners
Held before the run
5 payments, $496,200 in the hero case
target
15min
to rescreen every supplier and owner after a list change
Todayat the annual review
With agents≈ 14 min
typical
10days
to file an OFAC blocked or reject report; drafted the same day
Drafted on day 0
31 CFR 501.603 and 501.604

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (IEEPA civil maximum for 2025, the greater of $377,700 or twice the transaction, 90 FR 3687; name-screening false positives of roughly 85–95% of alerts, from vendor and KPMG benchmarks, directional only; reports of blocked property due within 10 business days, 31 CFR 501.603/604). Rules described: OFAC revised 50 Percent Rule guidance (13 Aug 2014); OFAC guidance on sham transactions and sanctions evasion (31 Mar 2026); EU Best Practices (July 2024); BIS Affiliates Rule (29 Sep 2025), suspended 10 Nov 2025 to 9 Nov 2026. People, companies, suppliers and list entries named on this page are fictional — characters and sample data in the working solution.

Questions

What sanctions and procurement leaders ask us.

What is Supplier Sanctions Screening?

Supplier Sanctions Screening checks every supplier and every owner behind it against the OFAC, BIS, EU, UK and UN lists on each list change, and applies the 50% ownership rules. Seven agents watch the lists, trace owners from registry documents, check each other's arithmetic and hold exposed payments before the run; the sanctions compliance officer confirms or clears each case with a reason and a signature.

How does it apply the OFAC 50 percent rule?

The ownership agent builds the supplier's owners from registry extracts, filings and declarations and adds up the stakes held by blocked persons, directly or indirectly. A holding company owned 100% by a listed person counts in full. The result is shown as a bar with the 50% line, every segment cites its passage, and a second agent recomputes it from the documents without seeing the first answer.

Does it handle the EU and UK ownership tests as well as OFAC?

Yes. A switch shows the same stakes under the US test (aggregate, 50% or more), the EU test (aggregate, 50% or more) and the UK test (one person, or persons acting jointly, more than 50%). Which tests apply is set for each paying entity, so a block for a US company can sit beside a control review for the EU and UK companies.

What about the BIS Affiliates Rule?

The rule is suspended until 9 Nov 2026, so the agents watch it and never enforce it. They work out which suppliers would be restricted if it returns on 10 Nov — in the working solution, suppliers 50% to 72% owned by Entity List companies — and onboarding shows the date and the exposure.

How does it cut false positives in name screening?

The screening agent compares each match field by field — name, country, registration number, business and owners — and proposes a clear when they differ, with the evidence. Below 0.80 it proposes a clear for a person to confirm, above 0.92 two people decide, and weak matches can be cleared together after a sample check. A cleared pair is not raised again unless either record changes.

Can it stop a payment to a blocked supplier?

The payment hold agent finds the supplier's open invoices, POs and scheduled payments in the ERP and pauses them under rule R-3 before the next payment run, showing what it paused and how to undo it. It never releases or makes a payment. A release needs a reason and a second approver.

Do people stay in control of hits, blocks and filings?

Yes. The agents propose, explain and draft; only people decide hits, blocks and clears, with a reason code and a signature that records its meaning. The report writer drafts OFAC reports and memos but never files or sends them, and every agent step and decision is on the audit trail.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your screening policy, the paying entities and their regimes, your ERP and procurement connections — and it goes live once every quality gate has passed. We will walk you through it on a sample of your own suppliers first.

See it on
your suppliers.

We'll run Supplier Sanctions Screening on a sample of your own supplier master and its owners.