Most Indian exporters who screen counterparties at all screen against OFAC SDN (the U.S. Treasury's Specially Designated Nationals list). It is the most famous list. It is also the most-cited reason for export compliance officers being told, by management, "we don't need to do that, we don't ship to the US." That logic only works if you are willing to bet your container on it.
The four lists, briefly
- OFAC SDN (Office of Foreign Assets Control, U.S. Treasury): ~15,000 entities. Most current. Updated weekly.
- UN Security Council Consolidated List: ~700 entities. Most narrowly-scoped: counter-terrorism, North Korea, Iran. Binding on all 193 UN member states under Chapter VII.
- EU Consolidated Sanctions List: ~3,500 entities. Broader: includes Russia, Belarus, Syria, regional designations. Updated as council regulations are published.
- UK HM Treasury Consolidated List: ~13,500 entities (post-Brexit divergence from EU). Includes Russia and Belarus measures the UK has gone further on than the EU.
Total unique entities across all four, after de-duplication: approximately 31,639. That is the count Darsavio runs against. Roughly half of them appear on only one of the four lists.
Why one list is not enough
Three scenarios where a clean screen on the wrong list ends in a hold.
Scenario one. You ship from Mundra to Algiers. The buyer's bank is in Algeria, the shipping line is French (CMA CGM), the container transships through Genoa. The line is subject to EU law. The transshipment touches Italy. If the buyer or any related party is on the EU consolidated list, the line will refuse the booking, usually after the container has moved inland. OFAC SDN does not protect you here.
Scenario two. You ship from Kochi to Dubai. The buyer's bank is in the UAE but maintains a USD nostro account with a New York correspondent bank. The bank will run OFAC. If the buyer is on the UK list, the bank may also run it as part of correspondent-bank compliance. The shipment moves; the payment does not.
Scenario three. The buyer is a clean company. The buyer's beneficial owner (the parent two layers up) is on the UN list. UN list compliance is mandatory in every UN member state including India. Discovered at the wrong moment, this is a regulatory matter for the Indian Directorate of Revenue Intelligence, not a commercial dispute.
How we run the screen
Three checks before any quotation leaves us:
- Direct entity match on the buyer's registered name (and any aliases the buyer provides).
- Address match on the buyer's principal place of business: addresses are on the lists too, and sometimes catch shell entities the names miss.
- Beneficial-owner check using public registries (Companies House for UK-linked entities, RUC databases in LATAM, SAT records in Mexico) for ultimate ownership disclosure.
The result of the screen (the four-list reference, the time stamp, the unique screening ID) is logged on every proforma invoice we issue. If a buyer ever asks "did you check?", we have the answer in writing.
What this means for buyers
You should ask any Indian exporter you talk to which sanctions lists they screen against. The answer "OFAC" is incomplete. The answer "we don't, our bank does" is wrong. Your bank checks the payment leg, not the cargo, and not the supply chain. The answer "OFAC, UN, EU, UK, logged on the proforma" is the floor of what you should accept.
— Nitik · Darsavio EXIM