Senserity Help

Owner sanctions match: what the check means

Why it matters when a person with significant control of a company matches the UK Sanctions List, how the check works, and what to do about a match.

Severity
Critical
Category
Compliance
Plan
Free and above
Test code
COM-032

What this test checks

Compares the individuals registered as persons with significant control of the company, its beneficial owners, with the individuals designated on the UK Sanctions List. A separate check (COM-033) does the same for corporate owners.

A designated owner is arguably more serious than a designated director: owners have a direct financial interest in the company, and a company owned or controlled by a designated person can itself fall under the sanctions.

What a fail looks like

An owner's name, and where available date of birth, matches a designated individual. If confirmed, the company may be treated as owned or controlled by a designated person.

Harmless explanations

  • As with any name-based screening, a common or transliterated name can match the wrong person.
  • A former owner who sold their interest before the designation may not affect the company today.

What to do

  • Compare the designation details with the owner's register entry, including month and year of birth and nationality.
  • Pause payments until the match is resolved.
  • If confirmed, take legal advice: ownership or control by a designated person can bring the company itself within the sanctions.

Background: Sanctions screening.

Part of the test catalogue. Every check Senserity runs, with its severity and the plan it is available on.

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