JURISDICTION SCREENING GUIDES · GUIDEUPDATED 2026-08-20
Jurisdiction Screening Guides
EU Sanctions Screening: Consolidated List and Restrictive Measures Workflow
How EU sanctions screening works — who adopts restrictive measures, what the EU consolidated list contains, the ownership and control test, and who is bound by the obligations.
EU sanctions screening checks people and companies against the restrictive measures adopted by the Council of the European Union. An EU sanctions regime begins as a Common Foreign and Security Policy decision under Article 29 of the Treaty on European Union; the elements that bind private parties — asset freezes and economic restrictions — are then given direct effect across the Union by a Council Regulation adopted under Article 215 of the Treaty on the Functioning of the European Union. Each regulation carries an annex naming the designated persons and entities, and the European Commission consolidates those annexes into the EU consolidated list of persons, groups and entities subject to financial sanctions, published in machine-readable formats for screening use. The European External Action Service publishes the EU Sanctions Map as the reference guide to which regime imposes what. The obligations apply to EU nationals wherever they are, to companies incorporated under the law of a member state, to anyone inside EU territory and to any business done in whole or in part within the Union. Enforcement, however, is national: member states designate competent authorities, and Directive (EU) 2024/1226 now sets a harmonised criminal floor for breach and circumvention.
What this workflow covers
SCOPE- Screen against the EU consolidated list of persons, groups and entities subject to financial sanctions, maintained by the European Commission and published in machine-readable formats.
- Use the EU Sanctions Map, published by the European External Action Service, to identify which regime applies to a country, sector or theme, and the EU Sanctions Tracker to search active listings.
- Understand the two-instrument structure: a CFSP Council Decision under Article 29 TEU sets the policy, and a Council Regulation under Article 215 TFEU makes the asset freeze and economic measures directly binding on private parties.
- Track effect on publication — designations enter into force when published in the Official Journal of the European Union, frequently on the day of adoption, so screening must run against the current list rather than a periodic snapshot.
- Apply the ownership and control test: EU guidance treats holdings of more than 50 percent as ownership, and separately treats the ability to direct an entity's affairs as control, either of which brings an unlisted entity within the asset freeze in practice.
- Observe both limbs of an asset freeze — freezing funds and economic resources belonging to a designated person, and the separate prohibition on making funds or economic resources available to or for the benefit of that person, directly or indirectly.
- Go beyond named persons: EU regimes also impose sectoral measures such as export and import bans, service bans and transport restrictions that apply regardless of whether a counterparty is designated.
- Check national measures layered on top of the EU list — member states can and do adopt additional national designations and restrictions administered by their own competent authorities.
- Report to the national competent authority of the relevant member state where a freeze is applied or a suspected breach identified; the reporting channel is national, not central.
- Document each check with the list version, the identifiers compared, the reviewer and the rationale, and keep circumvention indicators — sudden ownership restructures, new intermediaries in third countries — in the review record.
Key statistics
DATA- Adopting institution
- Council of the European Union (unanimity)
- Treaty on European Union, Article 29
- Directly binding instrument
- Council Regulation under Article 215 TFEU
- Treaty on the Functioning of the European Union
- Consolidated list maintained by
- European Commission
- European Commission
- Criminal enforcement floor
- Directive (EU) 2024/1226 on violation of Union restrictive measures
- Official Journal of the European Union
Compliance glossary
TERMS- Restrictive measures
- The formal EU term for sanctions. They include asset freezes and travel bans on designated persons and entities, and sectoral measures such as arms embargoes, export and import bans, service bans and transport restrictions.
- EU consolidated list
- The register maintained by the European Commission that consolidates the designations annexed to every EU sanctions regulation in force, published in machine-readable formats for use in screening systems.
- Asset freeze
- The prohibition on dealing with funds and economic resources belonging to, owned, held or controlled by a designated person, combined with the separate prohibition on making funds or economic resources available to or for that person's benefit.
- Ownership and control test
- The EU criterion for deciding whether an unlisted entity falls within the effect of an asset freeze: ownership is generally indicated by a holding of more than 50 percent, while control is indicated by the ability to exercise decisive influence over the entity's affairs.
- National competent authority (NCA)
- The member state body designated to implement and enforce EU restrictive measures nationally — granting derogations and authorisations, receiving reports of frozen funds, and applying penalties.
- Designated person
- An individual, group or entity named in the annex to an EU sanctions regulation and therefore subject to the measures that regulation imposes, most commonly an asset freeze and a travel ban.
Authoritative references
SOURCES- 01EU Sanctions Map
European External Action Service
- 02Overview of sanctions and related tools — consolidated list of financial sanctions
European Commission, DG FISMA
- 03Directive (EU) 2024/1226 on the definition of criminal offences and penalties for the violation of Union restrictive measures
Official Journal of the European Union
- 04EU sanctions policy — Council of the European Union
Council of the European Union
Expert perspective
NOTE“The EU consolidated list is a floor, not a ceiling — member states layer their own national measures on top, and programs that stop at the EU list miss that layer.”
Frequently asked questions
Q&A- What is the EU consolidated sanctions list?
- It is the single register that brings together the designations annexed to every EU sanctions regulation in force. The European Commission maintains it and publishes it in machine-readable formats for screening systems. Each entry carries the identifying details of the person or entity, the regime and the legal act under which it was designated, and the stated reasons for the listing.
- Who adopts EU sanctions?
- The Council of the European Union, acting unanimously. The Council first adopts a Common Foreign and Security Policy decision under Article 29 of the Treaty on European Union, then a Council Regulation under Article 215 TFEU to give the asset freeze and economic measures direct effect. The European External Action Service prepares proposals and the European Commission maintains the consolidated list.
- How often is the EU consolidated sanctions list updated?
- Whenever the Council adopts a new designation, amendment or delisting, which happens throughout the year rather than on a fixed calendar. Measures take effect on publication in the Official Journal of the European Union, often on the day of adoption, so screening programmes should refresh against the published list rather than rely on a periodic snapshot.
- Who must comply with EU sanctions?
- Nationals of EU member states wherever they are located, legal persons incorporated or constituted under the law of a member state including their branches, any person inside EU territory, aircraft and vessels under a member state's jurisdiction, and any legal person in respect of business done in whole or in part within the Union. A non-EU company can therefore be in scope through its EU-facing business.
- Does the EU have a 50 percent rule?
- The EU applies an ownership and control test rather than a single numerical rule. Council guidance treats a holding of more than 50 percent of proprietary rights or a majority interest as ownership, and separately treats the ability to exercise decisive influence over an entity's affairs as control. Either can bring an unlisted entity within the scope of an asset freeze in practice.
- What does an EU asset freeze actually prohibit?
- Two things. Funds and economic resources belonging to, owned, held or controlled by the designated person must be frozen, meaning no transfer, alteration, use or dealing that changes their volume, amount or destination. Separately, no funds or economic resources may be made available, directly or indirectly, to or for the benefit of that person — a prohibition that catches indirect payments and in-kind provision.
- What is the difference between the EU consolidated list and the EU Sanctions Map?
- The consolidated list is the operational dataset of designated persons and entities, maintained by the European Commission for screening. The EU Sanctions Map, published by the European External Action Service, is a reference tool explaining which sanctions regimes exist, what measures each contains, and which legal acts impose them. Screening runs on the list; regime interpretation runs on the map.
- Are EU sanctions the same as UK or US sanctions?
- No. Since the United Kingdom's departure from the EU it maintains its own autonomous list under its own legislation, and US programmes have always been separate. The lists overlap substantially but diverge on designation timing, scope and individual names. Treating any one of them as a proxy for the others leaves a gap that surfaces at exactly the wrong moment.
- What are the penalties for breaching EU sanctions?
- Penalties are set and applied nationally. Directive (EU) 2024/1226 harmonises the definition of criminal offences for violating and circumventing Union restrictive measures and sets minimum maximum penalties, with member states required to transpose it into national law. The Directive also covers circumvention conduct such as concealing ownership or failing to freeze funds when required.
- Do EU sanctions cover subsidiaries of designated companies?
- In effect, often yes. A subsidiary is not automatically listed, but where a designated person owns or controls it, making funds or economic resources available to that subsidiary can amount to making them indirectly available to the designated person. The assessment is fact-based and depends on ownership, control and whether the designated person would benefit.
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