You can screen your business partners against sanctions lists without paying for anything. The four major authorities each publish their lists online, with a free search tool, and you can check a name against all of them in a few minutes.
This guide shows you how to do that properly. Where to look, how to run the check so it holds up, and what to write down so the check still means something later.
It also shows you where the free method stops working. Not because the tools are bad but because they are accurate and official.
The method breaks for a quieter reason: manual screening starts from zero every morning. Nothing you did yesterday carries into today. Not the work, not the decisions, not the proof. What carries forward is the difference between a habit and a control.
Where to screen for free
The four key authorities publish the sanctions lists most European companies need to check. Each one is free, public, and searchable.
The EU Consolidated Financial Sanctions List is maintained by the European Commission. It covers everyone subject to EU asset freezes. The search interface is the EU Sanctions Tracker, which shows all designations currently in force. The list files themselves sit in the Commission's Financial Sanctions Database, and downloading them needs a free EU Login account. For checking names by hand, the Tracker is the one you want.
OFAC's Sanctions List Search is the US tool. It searches the SDN List and the other US lists. OFAC says the tool is not a substitute for appropriate due diligence and does not limit liability. The search is the start of the check, not the whole of it.
The UK Sanctions List is the UK source. It is run by the FCDO and replaced the older OFSI Consolidated List, which closed on 28 January 2026. If your notes still point at the OFSI tool, they point at a list that no longer updates.
The UN Security Council Consolidated List is the UN source, with a search tool and the full list in HTML, XML, and PDF. It is the shortest of the four, because only the Security Council can put a name on it. Every UN member state is obliged to apply it, which makes it the one list that follows you into any market.
Those four are the official sources, and they are largely the only external tools you need.
How to run a manual check properly
A name is not enough. Most failed checks fail because someone searched one spelling of one name and stopped. A proper screening starts with the identifiers, and not just the name.
Run the legal name and the trading name, because companies are often listed under one and known by the other. Run the names you hold for directors and owners, not only the company itself. Add any date of birth, country, or registration number you have, because those are what separate your business partner from a stranger who shares the name.
So one business partner is rarely one search. It is the legal name, the trading name, a few key people, run across four lists, with the match setting moved up and down. That is what a diligent screening looks like.
What to record so the check counts later
A search you cannot show later did not happen, as far as an auditor is concerned.
Recording the check means writing down what you did, so the decision can be reconstructed without you in the room. None of this exists unless you build it by hand. The free tools do not keep a log for you.
For every check, record six things. The date you ran it, the lists you searched, the exact terms you typed, the result the tool returned, the decision you reached, and who made it.
Take a supplier you clear on a Tuesday in March. Six weeks later a colleague asks why you cleared them. Without a record, you are reconstructing a search from memory, on a list that has changed since. With a record, you point at six lines and the question is closed in a minute.
This is not bureaucracy for its own sake. A defensible sanctions program needs records of what was checked, when, against which lists, and why the decision was made. The check and the record of the check are one task, not two.
When manual screening is genuinely enough
For some companies, the free method is the right method, and reaching for software would be over-engineering.
Manual screening holds up when three things are true at once. You have few business partners, so the daily workload stays small. The base barely changes, so you are not onboarding new names every week. And one person owns the check, runs it on a schedule, and logs every result.
If that describes you, the four official tools are enough. You do not have a screening problem. You have a screening habit, and as long as the habit holds, it works.
The question is whether it keeps holding as the first two conditions change. Most companies do not stay small and static. They add partners, enter markets, and the workload grows underneath a process that was sized for a smaller one.
The work that resets every day
Here is where the free method strains, and it is worth seeing the size of it before it happens to you.
Sanctions lists change often. A name that was clean yesterday can be listed today. So a check is only current on the day you run it, which means a real screening practice re-runs the check on a schedule, not once at onboarding. For most active business partner bases, daily re-screening is the practical baseline.
Manual screening does not let yesterday's work count toward today's. Each day starts at zero. So the daily workload is the full base, multiplied by the lists, every day.
Take eighty business partners across the four lists. That is three hundred and twenty manual lookups, every working day, before anyone reads a single result. Over a five-day week it is sixteen hundred. None of it carried over from the day before, because there is nothing to carry it.
Manual screening does not noticeably break. It just stops getting done. The daily check slips to weekly, the weekly to "when there is time." The gap between a list changing and your seeing it stretches out, and nobody ever decided to allow that. We cover the cadence question in full in how often companies should re-screen business partners for sanctions.
The decisions that reset too
Redoing the work is the cost you can count. Redoing the decisions is the cost you cannot.
Most names you check are not really matches. A common name returns a list of candidates who share it but are not your business partner. Try it now: run an ordinary name like Ahmed or Ivanov through any of the four tools and count what comes back. You will be handed a pile of people, and no method for clearing them.
Clearing that pile is a decision. You looked, you compared identifiers, you concluded this is not our customer. In a manual process, that decision lives in your head and then evaporates. Tomorrow the same name returns the same candidates, and you clear them again, from scratch, because last time's reasoning was never written down. A clean result is not the same as a correct one, and a correct one you have to re-derive every day is barely a result at all.
There is a second decision the official tools cannot make for you. A business partner can be clean by name and still be restricted, because it is owned or controlled by someone listed. The four search tools return only the listed names, so a clean search can be the wrong answer. The UK list page says it directly: prohibitions also apply to unlisted entities owned or controlled by a designated person. We go into the ownership and control test, and how it differs from a simple ownership percentage, in the EU sanctions control test and what the OFAC 50% rule misses.
What carry-forward actually changes
Step back and the pattern is clear. The free method gives you accurate lists and a way to search them. What it does not give you is memory. That is the difference between a habit and a control.
A habit depends on a person doing the same work again tomorrow. A control keeps the work, the decision, and the proof available after the person moves on to the next case.
Manual screening can work for a small, stable base with one committed owner. The official tools are free, accurate, and worth using. But the process has no carry-forward built into it. Yesterday’s cleared namesakes do not suppress today’s repeats. Yesterday’s reasoning does not become today’s audit trail. Yesterday’s work does not reduce tomorrow’s workload.
That is where the cost appears. Not in the search itself, but in the repetition around it. Every business partner you add increases the number of checks, the number of namesakes, and the amount of proof someone has to recreate by hand. Free screening is a good starting point. It is not automatically a scalable control.
When the free method stops fitting, the next question is not which tool searches fastest. It is which approach lets a decision, once made, stay made. That is the question worth taking into how to evaluate sanctions screening software.