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Tom Wang
Tom Wang

Posted on Originally published at tomcn.uk

Sanctions Screening API: OFAC vs UK vs EU Lists

In August 2026 OFSI fined Citibank's London branch £4,732,830.58, and part of the case came down to three letters. The bank's screening system did not treat "PAO Sovcomflot" in its customer records as a match for "Sovcomflot" on the sanctions list, so 32 accounts stayed unrestricted and 328 transactions worth about £5.4 million went through.

Most screening failures look like that: a legal-form prefix, a transliteration, a list update that arrived nearly fourteen hours late. The pages ranking for "sanctions screening API" are mostly vendor product pages that skip the official download URLs, the thresholds open-source engines ship with and the licence terms on the data. The counts below come from the OFAC, UK, EU and UN files as I downloaded and parsed them on 29 October 2026.

How Does Sanctions Screening Work in Payments?

A screening system keeps a local copy of one or more government lists, compares names (and ideally dates of birth, passport or IMO numbers) against it, and sends anything above a score threshold to an analyst who decides whether the hit is real.

Most firms screen at two points. Customer screening runs at onboarding and again whenever a list changes, because a customer who was clean on Monday can be designated on Tuesday. Payment screening checks every party in a transfer, intermediary banks and free text included, before the money moves. The hard part is the comparison: names are not identifiers, and every list writes them differently.

OFAC SDN List vs UK Sanctions List vs EU Consolidated List

The four lists a UK or EU payment firm usually screens differ in size, in scope and in what counts as an entry.

OFAC SDN UK Sanctions List EU consolidated (FSF) UN consolidated
Entries, Oct 2026 19,484 6,420 6,269 1,007
Individuals 7,529 4,070 4,490 733
Ships and aircraft 1,568 vessels, 342 aircraft 683 ships none none
Formats XML, advanced XML, CSV, fixed-width, PDF XML, CSV, ODS, ODT, HTML, TXT, PDF XML, CSV, PDF XML
Access Public, User-Agent required Public Public token in the URL Public, one-hour signed redirect
Entry ID integer uid UniqueID, e.g. RUS1653 logicalId, euReferenceNumber REFERENCE_NUMBER, DATAID

OFAC's list is the largest because it spans 72 programmes, with 6,346 entries under Russia EO 14024 alone, and carries 1,075 digital currency addresses. Only 5,743 UK entries impose an asset freeze: 668 of the 683 ships are under shipping sanctions only. Alert on every UK entry and your payments queue fills with vessels that freeze no funds. The EU file has no ship type at all.


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About the Author

I'm Tom Wang, an AI Developer & Fintech Developer — building AI agents, crypto payment infrastructure, and cross-border payout systems with Rust, Go, and TypeScript. Based in London, UK.

Currently open to new opportunities in fintech, crypto payments, and AI agent engineering.

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