Solution · Finance
Sanctions screening in finance
Before each payment, you need to establish whether the recipient is subject to sanctions. The making-available prohibition expressly forbids providing funds to sanctioned people and organisations. Am I Compliant checks payees, banks and business partners against the available sanctions lists and documents the result in an audit-proof PDF with a verification URL.
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Screen payees, banks and business partners against official sanctions lists before payment and document the result in an audit-proof PDF.
- Required regardless of company size
- 20 official lists from 18 jurisdictions
- GDPR
- Audit-proof PDF
Where in finance should you screen?
Before payment approval
Screen the recipient before funds are transferred.
New bank details
Screen the bank and recipient.
Reviews and audits
Provide evidence for each payment.
Why should finance carry out screening?
Because a payment is the most direct way of making funds available. This is precisely what the making-available prohibition forbids. Finance is therefore the final control point before a violation actually occurs.
Who should finance screen?
Payees, their affiliated companies, and the banks and payment service providers involved. The 50 percent rule also applies here: companies owned or controlled at a level of 50 percent or more by a listed person are also covered.
When should you screen?
Before payment approval and whenever new bank details are provided or payment details change. As sanctions lists change continuously, the time of screening is crucial. The certificate records it.
What are the penalties for a violation?
A violation of sanctions and the making-available prohibition is a criminal offence under Section 18(1) of the German Foreign Trade Act (AWG), punishable by three months to five years of imprisonment, or six months to ten years in particularly serious cases (Section 18(6a) AWG). Companies may additionally face a corporate fine of up to EUR 40 million (Section 19(7) AWG). Managing directors are personally liable for a fine of up to EUR 1 million if they breach their supervisory duties (Section 130(3) of the German Administrative Offences Act (OWiG)). Read more in Penalties for sanctions violations.
What related topics can you explore?
Which primary legal sources apply?
- Council Regulation (EU) No 269/2014, Article 2: freezing funds and the making-available prohibition
- Section 18 of the German Foreign Trade Act (AWG): criminal offences (German text)
- Section 19 AWG: administrative fines (German text)
- Section 130 of the German Administrative Offences Act (OWiG): supervisory duties (German text)
Check your first business partner in 30 seconds
Screening against 20 official sanctions and PEP lists from 18 jurisdictions, with an audit-proof PDF.
Create an account for your screening certificate. Result in 30 seconds.
Am I Compliant is an information and data processing service and does not provide legal advice. Results are research findings; the legal assessment and decision rest with the user.
Frequently asked questions
Am I Compliant is an information and data processing service and does not provide legal advice. Results are research findings; the legal assessment and decision rest with the user.