Source: EU Consolidated Sanctions List (CFSP), UN Security Council Consolidated List, OFAC SDN List, UK OFSI Consolidated List, Irish Department of Finance Designations · extracted 2026-09-01
Who controls the entity — and whether that person is sanctioned
Control verification in a cross-border transaction has two layers. The first layer establishes the formal ownership chain: who holds shares, who sits on the board, who holds a proxy. The second layer asks whether any person in that chain appears on an active sanctions list or qualifies as a politically exposed person.
These two questions are answered from different sources. Company registers establish the chain. Sanctions and PEP databases establish the status of each person in it. A shareholder check without a sanctions overlay leaves the control question half-answered.
Ireland presents a specific challenge. The country sits at the intersection of EU regulatory obligations, UK post-Brexit list divergence, and US extraterritorial sanctions reach. A counterparty incorporated in Dublin may have beneficial owners subject to OFAC designations, EU CFSP measures, or UK OFSI restrictions — simultaneously and under different legal thresholds. Establishing control means checking all three regimes, not one.
What the Irish regulatory framework requires
Ireland implements EU sanctions through Council Regulations with direct effect. The Department of Finance maintains a list of persons designated under Irish-specific statutory instruments. These designations are published in Iris Oifigiúil, the official Irish gazette, and on the Department's website.
EU sanctions are published in the Official Journal of the European Union and consolidated in the EU Sanctions Map maintained by the European External Action Service. This database is publicly accessible. What it does not provide is a structured, auditable extract tied to a named counterparty, with a timestamp, a methodology note, and a record of which identifier variants were queried.
The Financial Intelligence Unit of An Garda Síochána and the Central Bank of Ireland issue guidance on PEP identification obligations under the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010–2021. PEP status is not published in a single register. It is derived from official appointment records across multiple public bodies.
The four source layers in an Irish sanctions and PEP extract
Layer 1 — EU consolidated list. The EEAS EU Sanctions Map consolidates designations under all CFSP Council Regulations. Entries include name variants, dates of birth, passport numbers where available, and the legal basis for designation. The list is updated on each working day that a new Council Regulation is published.
Layer 2 — UN Security Council list. The UN 1267/1989/2253 Committee list and other Committee lists are incorporated into EU law by reference but maintained separately at un.org. Name transliteration variants require independent query logic.
Layer 3 — OFAC SDN and sectoral lists. US Treasury designations apply to transactions with a US nexus and to non-US persons facilitating prohibited transactions. The SDN list is updated on irregular schedules. Sectoral sanctions (SSI list) impose restrictions that do not amount to full blocking but affect specific transaction types.
Layer 4 — UK OFSI consolidated list. Post-Brexit, UK designations diverge from EU designations. A person delisted by the EU may remain listed by OFSI, or vice versa. For Irish counterparties with UK business connections, both lists require independent query.
PEP identification draws on Dáil and Seanad membership records, government appointment records, state body board appointments, and equivalent records for family members and known close associates as defined under the 2010–2021 Acts.
Where the sources disagree
Divergence between EU and UK lists is the most common source of inconsistency. Since January 2021, the UK has maintained an autonomous sanctions regime. Designations are not automatically mirrored. An entity removed from the EU list following a successful annulment action before the Court of Justice may remain on the OFSI list pending a separate UK review process.
OFAC and EU designations diverge on evidentiary thresholds and on the scope of affiliated-entity coverage. An entity that is 50%-plus owned by a designated person is automatically blocked under OFAC rules. EU rules apply a case-by-case analysis. The same ownership structure may produce different compliance conclusions under each regime.
PEP records present a different type of inconsistency. Appointment records held by individual state bodies are not consolidated into a single database. A person who held a senior role in a state-owned enterprise may not appear in parliamentary records. Cross-referencing requires querying each body's published appointment history independently.
The limit of what the sources allow
The EU Sanctions Map, OFAC SDN search, OFSI list, and UN list are each publicly accessible. What they do not provide, individually or together, is:
- A single query covering all four regimes simultaneously
- Confirmation that all name variants and transliterations have been checked
- A timestamped record of the query result suitable for compliance file documentation
- A PEP determination derived from official appointment records rather than commercial database inference
- An assessment of whether a negative result reflects absence from the list or a gap in identifier data
The ceiling of what the sources allow is stated before payment. A negative result on a sanctions query means the queried identifier did not match a listed entry at the time of query. It does not mean the person is not subject to sanctions under a different name variant, a different identifier, or a list not queried.
PEP status is a legal determination under Irish AML law. The extract establishes the factual record — appointment history, family relationships, known associate connections — from official sources. It does not constitute a legal determination of PEP status. That determination is the responsibility of the obliged entity under the 2010–2021 Acts.
What is included at each tier
| Tier | Price | What is included | Not included |
|---|---|---|---|
| Signal | €440 | EU consolidated list check (EEAS EU Sanctions Map), UN Security Council list check, OFAC SDN list check, OFSI UK consolidated list check — one named individual or entity; timestamped query record | PEP determination; Irish domestic designation check; name variant analysis beyond standard transliteration; second subject |
| Standard | €890 | All Signal content; Irish Department of Finance designations check; PEP identification from Dáil, Seanad, and government appointment records; name variant and transliteration analysis; up to three named subjects | State body board appointment records beyond central government; family member and close associate PEP mapping; adverse media layer |
| Extended | €1,800 | All Standard content; full PEP mapping including family members and known close associates per 2010–2021 Act definitions; state body appointment records; cross-border counterparty check in up to three additional jurisdictions; compliance-ready extract with methodology note and source citations | Legal advice; legal qualification of PEP status; representation before any authority; ongoing monitoring |
Frequently asked questions
What is the difference between a sanctions check and a PEP check? A sanctions check queries official lists of designated persons and entities subject to asset freezes, travel bans, or transaction restrictions. A PEP check identifies persons who hold or have held prominent public functions, and their immediate family members and known close associates. The two checks draw on different sources and serve different compliance purposes. They are combined in the Standard and Extended tiers because a counterparty may be a PEP without being sanctioned, or sanctioned without appearing in PEP databases.
How current is the extract? Each query is run at the time of order fulfilment. The extract records the date and time of each query. Sanctions lists are updated on irregular schedules; the EU list is updated on each working day a new Council Regulation is published. The extract reflects the state of each list at the moment of query, not at any earlier date.
Does a negative result mean the person is clear? A negative result means the queried identifier did not match a listed entry at the time of query on the lists covered by the tier ordered. It does not exclude the possibility of a match under a different name variant, a different identifier, or a list not included in the tier. The extract states which lists were queried and which identifier variants were used.
Why does the extract cover UK lists if the counterparty is Irish? An Irish-incorporated entity may have beneficial owners, directors, or transaction counterparties subject to UK OFSI designations. Post-Brexit UK and EU lists diverge. Omitting the UK list creates a gap in coverage for any transaction with a UK nexus or with persons who have UK connections.
Can the extract be used as compliance documentation? The extract is a factual compilation from official sources with timestamped query records and methodology notes. Whether it satisfies the documentation requirements of a specific obliged entity's AML programme is a question of that entity's internal compliance policy and the applicable regulatory guidance. The extract does not constitute legal advice.
How long does fulfilment take? Signal tier: one to two business days. Standard tier: two to three business days. Extended tier: three to five business days. Timelines assume all required identifiers are provided at the time of order.
Sources
- EU Sanctions Map (EEAS) — https://www.sanctionsmap.eu — extracted 2026-09-01
- UN Security Council Consolidated List — https://www.un.org/securitycouncil/content/un-sc-consolidated-list — extracted 2026-09-01
- OFAC Specially Designated Nationals and Blocked Persons List — https://ofac.treasury.gov/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists — extracted 2026-09-01
- UK OFSI Consolidated List — https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets — extracted 2026-09-01
- Irish Department of Finance — Financial Sanctions — https://www.gov.ie/en/organisation-information/4b4f0-financial-sanctions/ — extracted 2026-09-01
- Iris Oifigiúil — https://www.irisoifigiuil.ie — extracted 2026-09-01
- Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010–2021 — https://www.irishstatutebook.ie — verified 2026-09-01
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Disclaimer: This report is a factual compilation from official registers and public sources. It is provided for informational purposes only, does not constitute legal advice, and contains no legal qualification of the facts established. VLO Law Firm assumes no liability for actions taken or not taken based on this material. For advice regarding your particular situation, please contact info@vlolawfirm.com.
Author: James Whitfield — Partner, UK & Common Law, VLO Law Firm
