Control over a company begins with knowing who stands behind it. In Sweden, that question has a sanctions and PEP dimension that no ownership register answers on its own. A subject may hold no formal position, appear in no corporate filing, and still carry a designation that makes the transaction legally hazardous. This extract establishes whether that designation exists, across which lists, and at what confidence level.
The extract does not interpret consequences. It states what the sources show. The ceiling of what the sources allow is stated before payment.
What the extract coversEU Consolidated Sanctions List, UN Security Council Consolidated List, OFAC SDN List, Swedish national sanctions administered by Finansinspektionen, and PEP databases covering politically exposed persons and their close associates. Verified: 2026-09-15. Subject typesNatural persons and legal entities. Screening runs against name variants, aliases, and date-of-birth combinations where available in the source lists. Access conditionNo national identifier or Swedish registration is required to request a screening. The subject's full legal name and date of birth (for individuals) or registered name and jurisdiction (for entities) are sufficient to initiate the query. What the extract does not showAdverse media, criminal records, civil court judgments, and beneficial ownership chains. Absence from all lists does not constitute a clearance opinion.Sweden operates within the EU sanctions framework. The primary instrument is Council Regulation (EU) 2580/2001 and subsequent measures, consolidated in the EU Consolidated Sanctions List maintained by the European External Action Service. Alongside it, the UN Security Council Consolidated List applies directly. OFAC designations are a separate US-jurisdiction instrument but are routinely included in cross-border due diligence because counterparty banks in correspondent chains apply them independently of the transaction's governing law.
Finansinspektionen, Sweden's financial supervisory authority, administers national-level sanctions under the Act on Measures against Money Laundering and Terrorist Financing (2017:630). Finansinspektionen publishes its own list of designated persons and entities. This list may diverge from the EU consolidated list in timing: a national designation can precede or follow the EU-level action.
PEP status in Sweden is not maintained in a single official register. PEP databases are compiled by commercial data providers from public sources: parliamentary records, government appointment notices, Riksdag declarations of interest, and equivalent sources in foreign jurisdictions for non-Swedish PEPs. The extract draws on these compiled sources and states the database version and extraction date for each.
Source: EU Consolidated Sanctions List (EEAS) · extracted 2026-09-15
Source: UN Security Council Consolidated List · extracted 2026-09-15
Source: Finansinspektionen national sanctions list · extracted 2026-09-15
The screening runs in three stages. Each stage is documented in the extract.
Stage 1 — List matching. The subject's name and available identifiers are matched against each list. Matches are classified as exact, probable, or possible, based on name distance, date-of-birth alignment, and nationality or jurisdiction overlap. Each classification carries a confidence indicator.
Stage 2 — PEP determination. PEP status is assessed against the four-tier classification used in the EU Anti-Money Laundering Directives: senior political figures, senior executives of state-owned enterprises, senior officials of international organisations, and immediate family members or known close associates. The extract states the tier and the source entry.
Stage 3 — Cross-list reconciliation. Where a subject appears on more than one list, the extract maps the overlap and notes any divergence in designation date, listed reason, or asset-freeze scope. Divergence between lists is itself a finding, not an anomaly to be smoothed over.
The extract does not aggregate a single score. It presents each list result separately so that the reader can assess which lists are material to their specific transaction or counterparty relationship.
A sanctions designation or PEP classification attached to a beneficial owner, a director, or a significant shareholder affects the practical control structure of the company regardless of what the corporate register shows. A designated person cannot lawfully receive funds, cannot direct asset movements, and in many jurisdictions cannot hold a directorship without regulatory approval.
The extract identifies whether any named individual associated with the subject company appears on a relevant list. It does not trace the full ownership chain — that is a separate corporate structure report. What it does is answer the prior question: before the chain is traced, does any known principal carry a designation that changes the analysis?
In Sweden, the corporate register (Bolagsverket) records directors and registered shareholders. It does not screen them against sanctions lists. The extract fills that gap. Where the corporate register names a director and the extract returns a probable match on the EU Consolidated List, that combination is the finding.
Source: Bolagsverket (Swedish Companies Registration Office) · extracted 2026-09-20
Standard delivery is five business days from receipt of the subject's identifying information. Extended screening — covering additional jurisdictions, multiple subjects, or historical designation records — takes up to ten business days.
The extract is delivered as a structured PDF. Each list result is presented on a separate page with the source list name, the extraction date, the match classification, and the full list entry where a match is found. A cover summary states the total number of lists screened, the number of matches found, and the confidence classification of each match.
Sanctions lists are updated continuously. A designation issued after the extraction date will not appear in the extract. The extract states its extraction date for each list; that date is the boundary of what it can show.
PEP databases are compiled from public sources. A person who holds a qualifying position but whose appointment has not yet been published in a traceable official source will not appear. The extract states the database version and the date of the last update for each PEP source used.
Absence from all screened lists is a factual result. It is not a legal clearance. The extract does not state that a subject is not a PEP or not designated — it states that no match was found in the sources screened as of the extraction date.
The EU Consolidated Sanctions List does not include all national-level designations of EU member states. Sweden's Finansinspektionen list is screened separately. Other member-state national lists are not included in the standard extract; coverage of additional national lists is available at the Extended tier.
OFAC designations apply under US law. Their inclusion in this extract reflects standard cross-border due diligence practice. The extract does not assess whether OFAC rules apply to a specific transaction; that is a legal question outside the scope of this document.
Divergence between lists occurs in two patterns. First, a subject may appear on the UN list but not yet on the EU list, or vice versa, because the consolidation cycle introduces a lag. Second, a subject may appear on the Finansinspektionen national list under a designation that has not yet been replicated at EU level. Both patterns are material. The extract flags each divergence and states the date of each designation.
Where a PEP database entry conflicts with official public records — for example, where a database lists a person as a current senior official but the official source shows the appointment has ended — the extract notes the conflict and cites both sources. Resolution of the conflict is outside the scope of the extract.
| Tier | Price | What is included | Not included |
|---|---|---|---|
| Signal | €440 | EU Consolidated Sanctions List, UN Security Council Consolidated List, OFAC SDN List, Finansinspektionen national list; PEP screening against one primary database; single subject (natural person or legal entity); PDF extract with match classification; extraction date stated per list | Additional EU member-state national lists; second PEP database cross-check; multiple subjects; historical designation records; adverse media |
| Standard | €890 | All Signal content; second PEP database cross-check; up to three subjects in one extract; cross-list reconciliation section; divergence flags with dates | Additional EU member-state national lists; historical designation records; adverse media; legal interpretation of findings |
| Extended | €1800 | All Standard content; coverage of up to five additional EU member-state national lists (specified at order); historical designation records where available from source; up to ten subjects; adverse media summary from public sources; cover memo summarising findings across all lists | Legal qualification of findings; legal advice on transaction consequences; representation |
Does the extract cover Swedish politically exposed persons only, or also foreign PEPs? The PEP databases used include both domestic and foreign PEPs. A Swedish-registered company with a foreign beneficial owner who holds a qualifying political position in their home jurisdiction will be flagged if that person appears in the database. Coverage of foreign PEPs depends on the database's source coverage for the relevant jurisdiction; the extract states the database's stated geographic scope.
What identifying information is needed to run the screening? For a natural person: full legal name, date of birth, and nationality or country of residence. For a legal entity: full registered name and jurisdiction of incorporation. Additional identifiers — passport number, national ID, registration number — improve match accuracy and reduce false positives. They are not mandatory to initiate the request.
How current are the lists? Each list is extracted at the time of the order. The extraction date is stated in the extract for each list. Sanctions lists are updated without a fixed schedule; the extract reflects the state of each list on the extraction date only.
Is the extract sufficient for AML compliance purposes? The extract is a factual document. Whether it satisfies a specific compliance obligation depends on the applicable regulatory framework and the institution's own compliance policy. That determination is outside the scope of this document.
Can the extract be ordered for a company rather than an individual? Yes. Entity screening runs the registered name and known aliases against the same lists. For entities, the extract also notes whether any listed individual is identified in the source list as a director, owner, or associated person of the entity.
What happens if a match is found? The extract states the match, its classification, and the full list entry. It does not advise on consequences. Next steps — legal assessment, transaction structuring, regulatory notification — are outside the scope of this document and require separate legal instruction.
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: Elena Moretti — Partner, Continental Europe, VLO Law Firm