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.
Related tests
- COM-030Company Direct Sanctions Match
- COM-031Director Sanctions Match
- COM-033Corporate PSC Sanctions Match
- GOV-030PSC Registered Check
Part of the test catalogue. Every check Senserity runs, with its severity and the plan it is available on.
Last reviewed .