Supplier sanctions screening that finds the supplier blocked through its owners, and stops the payment before the run
No payment reaches a supplier blocked through its owners; every alert brings its evidence.
See one case, screen by screen ↓Supplier Sanctions Screening checks every supplier and every owner behind it against the OFAC, BIS, EU, UK and UN lists on each list change, and applies the 50% ownership rules. Seven agents watch the lists, trace owners from registry documents, check each other's arithmetic and hold exposed payments before the run; the sanctions compliance officer confirms or clears each case with a reason and a signature.
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Name screening checks the supplier's name against the lists. But under OFAC's 50 Percent Rule a company owned 50% or more, directly or indirectly and in aggregate, by blocked persons is itself blocked, and OFAC does not publish who those companies are. A supplier owned 30% by a listed company and 25% by a holding of a newly listed person passes every name check, and is blocked. The ownership lives in company registries, filings and the supplier's own declaration, often in another language, and it is usually checked once, at onboarding.
Meanwhile the alert queue is full of near-namesakes, so analysts stop reading the reasons and real hits wait behind false positives. The US, EU and UK tests give different answers for the same stakes. Accounts payable learns of a block after the payment run, and each payment is its own strict-liability violation. When OFAC asks why a payment was made or a match was cleared, the answer is spread across emails, screenshots and one analyst's memory.
Estimated hours of compliance, procurement and accounts payable time for one list change across a large supplier base, by hand and with the solution.
Seven agents watch the lists, trace every owner, check each other's arithmetic and hold payments; the sanctions officer decides and signs.
Kestrel & Vane Group pays 18,412 active suppliers. At 18:40 ET on 6 October, OFAC publishes an SDN update with 212 new entries. One of them, Rustam Vellin, is the sole owner of a shareholder of Orion Components Ltd, a precision-castings supplier in Limassol that Kestrel & Vane Industrial Inc. pays $2.9M a year. Here is what happens next, screen by screen, in the working solution.
The list watcher reads the OFAC update (212 added, 3 removed) and the UK list change of 11:30 (14 added) and starts a rescreen. The screening agent checks 18,412 suppliers and 46,930 owners and officers, with Cyrillic, Arabic and Chinese transliteration, and rebuilds ownership where an owner matched. Fourteen minutes later there are 9 potential matches, each with a proposed decision.
List watcher: “OFAC published an SDN update at 18:40 ET: 212 new entries, 3 removed. I started a rescreen of every supplier and every owner.”
Daniel opens Today: “Overnight the agents rescreened 18,412 suppliers and 46,930 owners against 226 new list entries. 7 things need you; the payment run is tomorrow at 10:00.” Each agent reports one item with its sources and one next step: Orion first, then a UK name match on Petrova Logistics FZE, a control question on Brightwell Alloys, an onboarding request, and the matches the agents propose to clear.
Ownership agent: “Orion Components Ltd is on no list, but is blocked through its owners: 55% under US rules. A second agent recomputed it and agrees. I paused 3 invoices, $410,000, before tomorrow's run.”
Orion's owners are one bar, each segment sized by its stake: Varkon Trading LLC 30%, held through Ardent Nominees Ltd and on the SDN list since 12 Mar 2025; Pellon Invest Ltd 25%, owned 100% by Rustam Vellin; Meridale Capital Partners SA 28% and 14 other holders 17%, with no match. The two listed segments add up to 55%, past the dashed line at 50%. Beside it: $410,000 paused before the 8 Oct run, and an OFAC report due 22 Oct 2026 if he blocks.
“55% blocked ownership · blocked under US (OFAC) rules”
The screening agent found no name hit on Orion or its two directors (best score 0.41), but Pellon's sole owner matches the new entry on name, date of birth and passport number. The ownership agent reads both registry extracts, resolves the nominee and writes out 30% + 25% = 55% (96% sure). The ownership verifier recomputes from the same documents without reading that answer, and agrees.
Ownership verifier: “I recomputed from the two registry extracts without reading the first answer: 30% + 25% = 55%. Agrees.”
Clicking the Pellon segment opens the Cyprus companies registry extract for Pellon Invest Ltd, company no. HE 412650, of 19 Aug 2026. The passages the agents used are highlighted: Rustam Vellin as the only shareholder, 1,000 shares or 100%, and as director, with his date of birth and passport number. A side panel shows which agents used the passage and for what: the screening agent, the ownership agent and the verifier.
The ownership map writes out how 55% is reached under each test. US, aggregate 50% or more: Varkon 30% + Pellon 25%, counted in full, so blocked. EU: Vellin is not on the EU list, so 30%, not owned. UK, one person more than 50%: 30%, not owned. The control and evasion agent adds that Orion's own declaration of 3 Feb 2026 names Ardent Nominees for the 30%, not Varkon, and suggests a control review for the EU and UK companies instead of a block.
The control and evasion agent never blocks on red flags alone; it always asks a person.
Daniel asks “Which payments are exposed?” The payment hold agent answers with the three invoices in Thursday's 10:00 run — INV-77120 $162,400, INV-77188 $131,600, INV-77231 $116,000 — all paused, and an open PO-55810 for $72,800 it has not touched. He types “Hold the open PO too”. The PO is held in the ERP, Marco Ferreira is told, and the total held for Orion is $482,800.
The payment hold agent pauses; it never releases a payment and never pays.
He picks the reason “Owned 50% or more by blocked persons (OFAC 50 Percent Rule)”, which is stored with his signature and goes into the evidence pack. The agents then turn the paused invoices into blocks, mark supplier V-104882 as blocked in the supplier master, draft the case memo for Rachel Ames and ask Aiko Tanaka for a control review in the EU and UK companies, due 14 Oct.
“Signing as Daniel Brooks, Sanctions Compliance Officer · Meaning: I have reviewed the evidence and make this decision.”
The report of blocked property is ready the same morning, due 22 Oct 2026 — 10 business days, Columbus Day excluded. Reporting entity Kestrel & Vane Industrial Inc., Cleveland, Ohio; why blocked, 55% owned by Varkon Trading LLC and Pellon Invest Ltd; property, 3 payables of $410,000 and PO-55810 for $72,800; every field cites its source. Daniel can sign and file it, or ask Rachel to review first.
“Drafted by the report writer; nothing is filed or sent without a signature.”
Payment holds shows Orion blocked and signed, $482,800 in four items; Petrova's two invoices, $86,200, paused and waiting for a decision; and Brightwell's PO-55642 for $54,900, not held, due in the 22 Oct run while its control review is open. The 8 Oct run, about $64M, goes ahead without the held items. Any release needs a reason and a second approver.
“The payment hold agent pauses; only people release.”
The same list change, seen by five of the people who carry it — what their week looked like, and what it looks like now.
Seven agents watch the lists, trace every owner, check each other's arithmetic and hold payments; the sanctions officer decides and signs.
Checks seven lists every 15 minutes — OFAC SDN and non-SDN, the BIS Entity List and Military End-User List, the EU consolidated list, the UK and UN lists, and your own do-not-deal list — sees what changed and starts a rescreen of every supplier, owner and officer.
Matches suppliers, owners and officers on names, aliases and transliteration, address, registry and tax numbers and dates of birth, and explains field by field why each match is or is not a hit.
Builds each supplier's ownership chain from registry extracts, filings and declarations, and computes the direct, indirect and aggregate blocked stake under the US, EU and UK tests.
Recomputes every block independently from the source documents and escalates any disagreement to a person with both workings.
Looks beyond 50% for the control and sham-transfer red flags in OFAC's March 2026 guidance: stake cuts near a listing, transfers to relatives, nominees, shared directors and declarations that contradict the registry.
Finds the open invoices, POs and scheduled payments for an exposed supplier in the ERP and pauses them under rule R-3 before the next payment run, showing what it paused and how to undo it.
Drafts OFAC blocked and reject reports, case memos, supplier notices, licence renewals and the monthly summary, and tracks the 10-business-day clock.
Decides and signs; two people release. The agents propose; a named person decides.
On Today and inside every case, the agents answer in plain words with their sources — and act when you tell them to.
What has to be decided before the payment run?
Two suppliers, both already paused: Orion Components Ltd, $410,000 (55% blocked ownership under US rules), and Petrova Logistics FZE, $86,200 (UK listing, 0.96). If you decide nothing, both stay paused and the run goes ahead without them.
Why does Pellon count in full?
Because Rustam Vellin owns 100% of Pellon Invest Ltd, Pellon is itself blocked, and OFAC counts a blocked entity's stake in full, not multiplied down. So Pellon's 25% of Orion counts as 25% blocked. Had Vellin owned only 40% of Pellon, Pellon would not be blocked and its stake would not count.
What changes under EU and UK rules?
Under the EU test only Varkon is listed, so the listed share is 30%, below 50%. Under the UK test one designated person must hold more than 50%; Varkon's 30% does not. So Kestrel & Vane's EU and UK companies are not barred by ownership, but the nominee arrangement is a control question.
Who else do we pay that Varkon or Vellin owns?
One other supplier: Castellan Forge Srl (Italy), 8% owned by Varkon Trading LLC. 8% is far below every line and there are no red flags, so it stays clear and on watch. Rustam Vellin owns nothing else we pay.
13 screens from the working solution, on its sample data. Pick one to see it large.
Every threshold, test and rule is a setting. Each change is saved as a new version and logged, and decisions keep the version they were made under.
| Setting | Default | Choose from |
|---|---|---|
| Propose a clear below this score | 0.80 | the agent still shows its evidence; a person confirms |
| Two people decide above this score | 0.92 | clearing a strong match needs a second person |
| Ownership tests by paying entity | US: OFAC · EU: EU · UK: UK | OFAC aggregate 50% or more · EU aggregate 50% or more · UK one person, or persons acting jointly, more than 50% |
| BIS Affiliates Rule | Suspended until 9 Nov 2026 · pre-compute exposure on | pre-compute who it would catch, block no one · off |
| R-1 · Rescreen on every list change | On | suppliers, owners and officers |
| R-3 · Pause payments at 50% blocked ownership | On | under any test that applies to the paying entity · reversible · tells AP and compliance |
| R-4 · Control review after a stake drop | On | when a listed owner drops below 50% within 90 days of a listing |
| Clocks | True hit within 4 business hours | ownership block before the next payment run · control review within 5 business days · OFAC report within 10 business days · licence reminder 30 days before expiry |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (IEEPA civil maximum for 2025, the greater of $377,700 or twice the transaction, 90 FR 3687; name-screening false positives of roughly 85–95% of alerts, from vendor and KPMG benchmarks, directional only; reports of blocked property due within 10 business days, 31 CFR 501.603/604). Rules described: OFAC revised 50 Percent Rule guidance (13 Aug 2014); OFAC guidance on sham transactions and sanctions evasion (31 Mar 2026); EU Best Practices (July 2024); BIS Affiliates Rule (29 Sep 2025), suspended 10 Nov 2025 to 9 Nov 2026. People, companies, suppliers and list entries named on this page are fictional — characters and sample data in the working solution.
Supplier Sanctions Screening checks every supplier and every owner behind it against the OFAC, BIS, EU, UK and UN lists on each list change, and applies the 50% ownership rules. Seven agents watch the lists, trace owners from registry documents, check each other's arithmetic and hold exposed payments before the run; the sanctions compliance officer confirms or clears each case with a reason and a signature.
The ownership agent builds the supplier's owners from registry extracts, filings and declarations and adds up the stakes held by blocked persons, directly or indirectly. A holding company owned 100% by a listed person counts in full. The result is shown as a bar with the 50% line, every segment cites its passage, and a second agent recomputes it from the documents without seeing the first answer.
Yes. A switch shows the same stakes under the US test (aggregate, 50% or more), the EU test (aggregate, 50% or more) and the UK test (one person, or persons acting jointly, more than 50%). Which tests apply is set for each paying entity, so a block for a US company can sit beside a control review for the EU and UK companies.
The rule is suspended until 9 Nov 2026, so the agents watch it and never enforce it. They work out which suppliers would be restricted if it returns on 10 Nov — in the working solution, suppliers 50% to 72% owned by Entity List companies — and onboarding shows the date and the exposure.
The screening agent compares each match field by field — name, country, registration number, business and owners — and proposes a clear when they differ, with the evidence. Below 0.80 it proposes a clear for a person to confirm, above 0.92 two people decide, and weak matches can be cleared together after a sample check. A cleared pair is not raised again unless either record changes.
The payment hold agent finds the supplier's open invoices, POs and scheduled payments in the ERP and pauses them under rule R-3 before the next payment run, showing what it paused and how to undo it. It never releases or makes a payment. A release needs a reason and a second approver.
Yes. The agents propose, explain and draft; only people decide hits, blocks and clears, with a reason code and a signature that records its meaning. The report writer drafts OFAC reports and memos but never files or sends them, and every agent step and decision is on the audit trail.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your screening policy, the paying entities and their regimes, your ERP and procurement connections — and it goes live once every quality gate has passed. We will walk you through it on a sample of your own suppliers first.
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1-min demoWe'll run Supplier Sanctions Screening on a sample of your own supplier master and its owners.