Is the company or any of its directors on a sanctions list?
Sanctions list check is part of customer due diligence, not a separate assessment
This question appears in virtually every questionnaire from a bank or a customer that is themselves subject to the Wwft, and by definition the answer is time-bound: it concerns the current status at the moment of completion, not a permanent fact. There is no "yes, permanently no" — sanctions lists are continuously updated, so what is correct today may be different next month. In practical terms, this means that with each new questionnaire you check again, even if you answered "no" half a year ago.
What the asking party actually wants to know is whether your company and the persons directly associated with it — directors, and often also the beneficial owners of the company — appear on one of the lists that banks and institutions are obliged to consult during their own customer due diligence. Screening against the EU sanctions list and comparable lists (OFAC, national lists) is something you can have carried out yourself or often have already had done by your own bank when opening an account. The result of that — a screening report or a declaration from your bank — is the supporting document you enter here. If you do not have that, then "no, not checked" is a more honest answer than an unsupported "no, not on the list". This subject also touches on the question of whether someone is a politically exposed person is: both questions are part of the same check for integrity risks, but are legally separate questions each with their own evidence.
Where this follows from: the customer due diligence of the Wwft
The obligation to screen customers (and thus also their directors and beneficial owners) against sanctions lists lies with the institution carrying out the customer due diligence — usually the bank or financial institution you do business with — on the basis of the Act on the Prevention of Money Laundering and Terrorist Financing. As a company you provide the data for this and possibly evidence that this screening has already taken place; you do not yourself declare that you are "clean", you confirm what has resulted from a check.
What this is based on
The regulation itself is on EUR-Lex. We refer for each claim; you do not have to take our word for it.
What you concretely need to do
The implementation of each obligation, with the deadlines involved and the templates for recording it, is included in the subscription.
View the subscription First the free quick-scanThis is not legal advice. This page provides general information on the regulations this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections receive priority.