## TL;DR

Paying a sanctioned entity creates legal liability, so screening belongs in vendor onboarding before any payment. Check the vendor's legal name, owners, and country against the relevant lists (OFAC, EU, UN), document the screening result, and re-screen periodically and on data changes. False positives get cleared with documented evidence, not ignored.

## Steps

1. Collect the vendor's legal name, country, and ownership.
   Expected: Screening inputs.
2. Run against OFAC, EU, and UN lists (plus local equivalents).
   Expected: Screening results.
3. Clear false positives with documented evidence.
   Expected: A clean record.
4. Block onboarding on true matches and escalate to legal.
   Expected: Compliance.
5. Re-screen on data changes and annually.
   Expected: Ongoing coverage.

## When to use

- Vendor onboarding
- New countries or entities
- Compliance audits

## When not to use

- Per-transaction screening (separate control)
- Employee screening
- Customer screening

## Compatibility

Screening providers (Dow Jones, WorldCheck, etc.); ERP-agnostic process.

## Variant phrasings

### OFAC vendor screening

### sanctions check new supplier

### watchlist screening AP

## Root cause

Sanctions liability attaches to the payment. Onboarding is the last cheap checkpoint before money moves.

## Edge cases

- Name transliteration creates false positives; use structured matching
- Ownership thresholds vary by regime; know yours
- Screening providers differ in list coverage; validate coverage

## Provenance

Resolved from the public thread: https://vectle.com/posts/pst_zvJ5etWO6JuxkhjOGbYaaA