You type a company name into a sanctions search, nothing comes back, and the deal moves forward. That result is worth something, but on its own it is not an AML check. Here is what an AML check on a counterparty really covers, how much of it you can run yourself at no cost, where free screening stops working, and what an AML risk score actually measures.
An anti-money-laundering check answers a narrow question with expensive consequences: is there anything about this company, the people behind it, or the route the money takes that would make paying it a legal or financial problem. Banks run a version of this before they open an account. Compliance teams run it before a contract is signed. Anyone sending a serious prepayment to a company they have never met is doing the same thing, with or without a process.
Most of the first pass is free. The main sanctions lists are public, searchable and updated by the bodies that issue them. What free screening will not do is tell you when a clean result is meaningless, and that is where most of the damage happens.
Five layers make up a real check, and skipping any one of them leaves a gap someone can walk through.
Sanctions. Whether the company or any person connected to it appears on a designation list. PEP status. Whether an owner or officer is a politically exposed person, meaning a current or former public official or a close associate, which raises the corruption and compliance bar rather than blocking the deal outright. Adverse media. Serious allegations that have been reported but have not yet produced a listing. Ownership. Who stands behind the entity, because that is where control and therefore exposure sits. Jurisdictions. Which countries the ownership and the payment route pass through, since a chain that touches a high-risk or transit jurisdiction changes the risk profile regardless of how the local entity looks.
The single most common mistake is screening the company name and stopping there. Sanctions attach to individuals at least as often as to entities, and ownership rules mean exposure can pass through a person who was never named on the invoice. A supplier with a spotless corporate record whose majority owner is designated is not a clean counterparty. You have to screen the owners, one at a time, by name.
Every list below is maintained by the authority that issues the designations, published openly and searchable without a subscription. Between them they cover the designations that matter for most cross-border deals.
| Source | What it screens | Access |
|---|---|---|
| OFAC SDN list (US) | US designations, covering companies and individuals alike, including entities owned by designated persons. | Public |
| EU consolidated list | EU designations applying across all member states. | Public |
| UN Security Council list | UN designations that member states are required to implement. | Public |
| UK OFSI list | UK financial sanctions targets. | Public |
| Ukraine sanctions register (NSDC) | Ukrainian designations against entities and individuals, which govern local enforcement. | Public |
| Adverse media | Court reporting, press coverage and local-language reporting that surfaces long before any listing does. | Public, language-dependent |
PEP screening is the one layer with no clean free answer in Ukraine. There is no official state register of politically exposed persons, so PEP screening relies on public and community-maintained sources rather than a government list. They are useful and widely used, but treat a hit as a lead to confirm rather than a finding, and treat the absence of a hit as weak evidence.
Start by fixing the identity. Take the exact legal name and the registration code your counterparty gave you and match them in the state register. This sounds trivial and is not: common company names repeat across dozens of live entities, and screening the wrong one produces a confident result about a company you are not dealing with. The registration code is what makes every later step point at the right target.
Then pull the declared owners. The register gives you shareholders, directors and the declared beneficial owner, which is your list of names to screen. If the ownership chain leaves the country, note each company in it, because those entities need screening too. The declaration is a claim rather than a verified fact, and the deeper method for testing it is in our guide to checking the ultimate beneficial owner of a Ukrainian company, the ownership half of any serious AML check.
Now screen. Run the company and each owner against all five lists. Search by transliteration variants as well, because a name written one way in a register can appear differently on a designation list. After the lists, search adverse media, and search it in Ukrainian and Russian as well as English. Finish by recording what you did: which name, which list, which date, and what came back. That record is the only thing that turns a search into a check you can produce later.
Free screening has a hard ceiling, and it is worth being precise about where it sits.
Sanctions lists only name entities that have already been designated. A front company incorporated last year has not been designated, so it passes every list cleanly. That clean result is exactly what the structure was built to produce. Nominee owners and layered offshore holdings do the same job on the ownership side: the declared owner screens clean because the declared owner is not the person in control.
Transit jurisdictions are the specific version of this problem in the region. Since 2022, ownership routing back to Russia or Belarus has commonly been rebuilt through Georgia, Armenia, the UAE, Turkey or Kazakhstan. The local entity looks clean in its own registry, the intermediate company is recent and unremarkable, and the exposure sits at the far end of the chain where a list-based search never looks.
Language is a quieter failure. Serious allegations about a Ukrainian company usually appear in Ukrainian or Russian first, often in court reporting or regional press, sometimes years before any designation. An English-only search returns nothing and reads as a clean result. Finally, evidence: a screenshot with no source, no timestamp and no method behind it is not evidence in a compliance file. If a regulator or a bank asks how you reached your conclusion, the answer has to be reconstructable.
An AML or risk score is a weighted rating, not a verdict. It compresses several findings into one number so that a decision-maker can act without reading forty pages, and its value depends entirely on what went into it.
Our own Argus Score runs from 0 to 100. A score of 0 to 30 means high risk, 31 to 60 means medium, 61 to 80 means acceptable, and 81 to 100 means low risk. It weighs legal status, ownership structure, sanctions exposure, financial condition and reputation, so a company can be legally spotless and still score badly because its ownership is opaque or its litigation record is heavy.
Two things are worth saying plainly about any score, ours included. A score is only as good as the sources underneath it, so a number produced from a single automated list search carries very little information. And a defensible score has to document what fed it: which source, checked when, saying what. Without that, a score is an opinion with a number attached, and it will not survive the first serious question from a bank or an auditor.
For a small order from a supplier you can afford to lose, the free sequence above is a reasonable check and you should run it. The calculus changes when you have to show your work rather than simply believe it.
Four situations move the bar. Bank onboarding, where the institution will ask what you checked and expect a file. An audit or a regulatory request, where the standard is documentation rather than recollection. A large prepayment, where the loss is real money and the counterparty is new. And an acquisition, where you are buying the history along with the company, including liabilities nobody volunteered. In each of these, an unsourced screenshot is not an answer.
Run the free sequence first. The lists are open, the state register gives you the names, and for routine, low-value business that may genuinely be enough. It is also the compliance layer of the broader six-step guide to verifying a Ukrainian company, which covers the court record, the debt position and the physical footprint around it.
The work changes when the clean result stops being convincing. Tracing a nominee through holdings in three jurisdictions, screening every person in the chain, reading local-language court reporting and documenting each source to a standard that survives audit takes tools, languages and time most buyers do not have before a deadline. That is what a full check is for. Our Standard Report ($349) screens the company and its owners against sanctions, PEP and adverse media, traces the ownership chain, and delivers a PDF with a sourced verdict and an Argus Score, usually within 4 to 24 hours. A Basic Check ($149) covers the essentials, and Premium ($799) adds the deeper cross-border work. You can request a check or ask a question first.
An AML check is five layers, not one search: sanctions, PEP status, adverse media, ownership and jurisdiction. Most of the first pass is free, and you should run it, screening every owner by name rather than the company alone. Understand what free cannot reach: an undesignated front company, a nominee, a chain routed through a transit jurisdiction, and reporting in a language you did not search. When the decision has to be defended to a bank, an auditor or your own board, the difference between a search and a documented check is the whole point.
The Standard Report screens the company and its owners against sanctions, PEP and adverse media, traces the ownership chain, and delivers a sourced PDF verdict with an Argus Score — from $349, usually within 4–24 hours.