It is the systematic comparison of a customer's, executive's or counterparty's identity against sanctions lists, asset freezing lists and politically exposed person lists, in order to detect any match requiring action.

Which lists must be checked?

At minimum the consolidated EU sanctions list and the French national asset freezing register. Depending on exposure, you must also integrate OFAC lists and sources on politically exposed persons.

What should be done in case of confirmed match?

The funds in question must be frozen without delay, the transaction must be blocked, no resources must be made available to the targeted person and it must be reported to the competent authorities, in particular the General Directorate of the Treasury.

How to manage false positives?

Name matches are frequent. Analysis of supplementary data (date of birth, nationality, aliases) makes it possible to rule out false positives. The decision to dismiss an alert must be documented and traced.

How often should screening be performed?

Screening is performed at onboarding and then on a continuous basis, as lists are updated regularly. A customer who is compliant today may be added to a list tomorrow; periodic re-screening of the portfolio is necessary.

Sanctions & Asset Freezing

Sanctions lists and asset freezing: screening your clients and flows

Beyond identity verification, any regulated entity must ensure that its clients, managers and beneficial owners do not appear on a sanctions list and are not subject to an asset freezing measure. This guide explains how screening works, which lists to check and the obligations arising from a match.

Updated on July 31, 2026

Legal framework for sanctions and asset freezing

Restrictive measures (sanctions) are adopted by the European Union, often in implementation of United Nations decisions, and have direct application in Member States. In France, the Directorate General of the Treasury implements national asset freezing measures and publishes the national register of persons and entities subject to a freeze. Any person holding funds belonging to a frozen person must immobilize them without delay and report it. The US OFAC lists furthermore have extraterritorial reach that may affect European actors, particularly for dollar transactions. Failure to comply with a freezing measure exposes one to severe criminal and administrative penalties.

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EU Regulations imposing restrictive measures: consolidated list of Union sanctions.
Monetary and Financial Code (art. L. 562-1 et seq.): asset freezing and prohibition on making funds available.
Directorate General of the Treasury: national register of freezes and implementation in France.
OFAC (United States): SDN lists with extraterritorial reach, notably for dollar flows.

Elements to screen against the lists

Identity of natural person clients (name, first name, date and place of birth).

Legal entity clients and their names, including variants and aliases.

Managers, legal representatives and beneficial owners of companies.

Counterparties and beneficiaries of transactions and transfers.

Status of politically exposed person (PEP) and close associates.

Geographic elements: countries under embargo or subject to sectoral restrictive measures.

The stages of screening

1
Constitution of reference lists
Aggregation and updating of sources: consolidated EU list, national freezing register, OFAC lists and PEP sources.
2
Screening at onboarding
Comparison of the customer's identity and beneficial owners against lists, with management of name matches and aliases.
3
Match processing
Analysis of alerts to rule out false positives and confirm actual matches before any decision.
4
Freezing, blocking and reporting
In case of confirmed match, funds are frozen, the transaction is blocked and the competent authorities are notified.

Frequently asked questions

What is screening?: It is the systematic comparison of a customer's, executive's or counterparty's identity against sanctions lists, asset freezing lists and politically exposed person lists, in order to detect any match requiring action.
Which lists must be checked?: At minimum the consolidated EU sanctions list and the French national asset freezing register. Depending on exposure, you must also integrate OFAC lists and sources on politically exposed persons.
What should be done in case of confirmed match?: The funds in question must be frozen without delay, the transaction must be blocked, no resources must be made available to the targeted person and it must be reported to the competent authorities, in particular the General Directorate of the Treasury.
How to manage false positives?: Name matches are frequent. Analysis of supplementary data (date of birth, nationality, aliases) makes it possible to rule out false positives. The decision to dismiss an alert must be documented and traced.
How often should screening be performed?: Screening is performed at onboarding and then on a continuous basis, as lists are updated regularly. A customer who is compliant today may be added to a list tomorrow; periodic re-screening of the portfolio is necessary.

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