CBL Insights · Sanctions

What a Sanctions Review of a Transaction Should Cover

Checking public sanctions lists is only one step. The decision also depends on ownership and control, the subject matter, banks, payment flows and the contract.

Sanctions ComplianceAuthor: Cross-Border LawPublished: 11 June 2026

Record the scope of the review

A useful review records the parties checked, the ownership information available and the proposed goods, services and payment arrangements. It should identify information gaps and the date of the assessment. Changes to a party, owner, bank or transaction may require further review.

Information needed for the review

A list search does not cover every restriction. The review also needs information on ownership, the activity and how the transaction will be performed.

Names

The direct parties and connected persons.

Ownership and control

Direct, indirect and practical control.

Subject matter

Goods, services, technology, destination and use.

Payment

Banks, intermediaries, currency and documents.

Contract

Evidence, notice and a lawful response to restrictions.

Need to determine whether a transaction can proceed?

A Sanctions Risk Review provides a documented assessment and practical conditions for the decision.

Assess sanctions risk