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EU Sanctions Screening 2026/2027 – Customer, Ownership Chain and Transaction Blocking | Word/PDF/Excel
EU Sanctions Screening 2026/2027 – Customer, Ownership Chain and Transaction Blocking | Word/PDF/Excel
- File format
- DOCX, PDF, XLSX
- Document language
- Five Swedish workbooks Swedish user guide English User Guide for Swedish files and Swedish Excel
- Number of files
- 7
Digital download. No physical product is shipped.
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About this template
How do you check whether a customer, supplier, beneficial owner or transaction may be subject to EU sanctions? This specialist package enables Swedish companies to document a risk-based review of sanctions lists, ownership chains, effective control, trade and transport risks, and decisions to approve further review, investigate or block a transaction.
The product is specifically designed for importers, exporters, wholesalers, procurement functions, e-commerce companies and compliance officers. It is a manual decision-making and audit trail, not a database of current sanctioned persons or a program that automatically reviews transactions.
Package contents
01 Sanctions procedure & risk-based scoping; 02 EU list match & false positive protocol; 03 Ownership chain, beneficial owner & effective control; 04 Enhanced review of export, transaction & circumvention risk; 05 Transaction blocking, regulatory contact & re-review; 06 Swedish user guide; 07 English User Guide. All seven documents are available in editable Word (DOCX) and searchable, printable PDF. In addition, there is 08 Excel – sanctions and evidence register with nine tabs. Total of 15 customer files (7 Word + 7 PDF + 1 Excel).
What the files contain
Time of check and source version, verification of true identity in the event of a list match, indirect ownership links, effective control even in cases of ownership under 50%, counterparty and goods prohibitions, red flags for transport routes and third-party payments, investigation status, decision certificate, transaction blocking and reference to protected evidence. The Excel file compiles eight indicators without storing sensitive raw data.
What is included – file by file
| Document | Practical use | Format |
|---|---|---|
| 01 Sanctions procedure | Define which parties, countries, goods, services, transport and payments are to be checked. Define which EU regime applies. | SV · DOCX + PDF |
| 02 List match and false positive | Investigate name similarity, identity details, list source, legal act and verified check result without guessing. | SV · DOCX + PDF |
| 03 Ownership chain and effective control | Document direct and indirect ownership, beneficial owners, voting rights and effective control. No general 50% threshold is used. | SV · DOCX + PDF |
| 04 Circumvention risk | Review intermediary companies, changed delivery route, end user, goods code, third-party payment and other risk indicators. | SV · DOCX + PDF |
| 05 Transaction blocking and regulatory contact | Record decisions to investigate, stop, freeze according to the applicable provision and, if necessary, contact the appropriate competent authority. | SV · DOCX + PDF |
| 06 Swedish user guide | Step-by-step method, source matrix, document map, six stress tests and limitations. | SV · DOCX + PDF |
| 07 English User Guide | English-language guidance explaining the Swedish templates and register. No translated English compliance forms are included. | EN · DOCX + PDF |
| 08 Excel register | Nine tabs with counterparties, list checks, ownership chains, transactions, red flags, blocking decisions, actions and overview. | SV · XLSX |
Excel – nine tabs with eight warning indicators
Counterparties · List checks · Ownership chains · Transactions · Red flags · Blocking decisions · Actions · Overview · Read me. Status options and formulas show, among other things, possible list matches, open ownership control, unclear goods reviews, active risk indicators, blocked transactions, open regulatory issues and blocked actions.
The workbook is scenario-tested with synthetic data and delivered without it. A zero on the overview simply means that no relevant status has been registered. It is not a statement that the transaction is permitted. Only register internal case IDs and references to protected documents, not names, personal identity numbers, bank accounts or private investigation details.
Legal basis in Sweden 2026–2027
The Swedish Act (2025:327) on International Sanctions came into force on 10 June 2025. It implements EU Regulation 2024/1226 and contains criminal provisions on violations of international sanctions. It does not prescribe that all companies must use a specific Word or Excel form.
Current EU sanctions regulations govern what is prohibited. A business owner must check which regime, legal act, article and factual situation is affected. Sanctions may concern financial assets, persons and entities, goods, technology, certain services, trade or payment flows. A negative match on a specific person list is therefore not a complete clearance. Use the European Commission's updated sanctions resources and consolidated financial sanctions list together with the current legal act via EUR-Lex.
Ownership and control: A company that is not itself listed can still be affected by financial restrictions through ownership or effective control by listed persons or entities. Thresholds and legal consequences must be assessed against the specific sanctions regime. An ownership share under 50% does not automatically mean there is no control or risk. Document 03 helps you collect genuine sources – it does not draw any automatic legal conclusions.
Risk-based due diligence: The European Commission published guidance on the review of business partners, transactions and goods on 19 February 2024, particularly for export-related circumvention risks. The guidance is a practical aid and is not a general, binding standard form. The Swedish Agency for Economic and Financial Policy describes how directly applicable EU regulations, exemptions and Swedish regulatory roles work.
Competent authority: For certain economic sanctions, the Swedish Financial Supervisory Authority receives information on frozen assets and handles certain permits. The Swedish Police, Swedish Customs or another authority may be appropriate for other sanctions. The template does not automatically select an authority and does not send any notifications.
Recommended approach
- Define which parties and which goods, services and payment links are affected.
- Check the current EU legal act and perform genuine register checks with date, source and version reference.
- Verify list matches through actual identity; document false positives or remaining uncertainty.
- Assess indirect ownership and control, including intermediary companies, voting rights and changed ownership structures.
- Assess circumvention risk such as illogical transport routes, new intermediaries or third-party payers.
- Make a traceable decision: review further, investigate further or block. Assess freezing and regulatory requirements separately.
- Re-review in the event of new listings, changed ownership, different destination, new payment arrangements or other risk indicators.
Frequently asked questions
Is there a statutory obligation to use this specific sanctions check template?
No. The product is a practical documentation aid. The material obligations depend on which EU sanctions actually apply and whether your business or transaction is covered.
Is it enough to search the company name against a sanctions list?
No. Identity, alternative names, indirect owners, effective control and any goods and trade prohibitions may need to be reviewed.
Is a company automatically approved if a listed person owns 49 percent?
No. The legal significance of ownership and control is regime-specific. Effective control can play a role even without majority ownership.
Is every list match a confirmed sanctions violation?
No. Name similarity can cause false positive matches. Identify the correct person/entity, relevant legal act and applicable prohibition.
Does the package include an up-to-date list of sanctioned persons?
No. Lists can change often. Perform checks in official, up-to-date sources or in a validated separate screening system.
Does the package also apply to individuals' international payments?
The templates are designed for companies and their business flows, not as a private payment service, bank review or general legal advice.
Are the PDF files digitally fillable?
No. They are searchable and printable. Edit Word and Excel.
Can you get English work templates?
The five operational work templates and Excel are in Swedish. An English-language guide explains the Swedish files.
Related documents on Mallbutiken
For general review of suppliers' quality and capability, there is Supplier Assessment and Follow-up. For obligations under anti-money laundering regulations, there is the AML/KYC package. For trade documents, there is Proforma Invoice and Export Documentation. This product has a more defined function: EU sanctions check of transaction, ownership and blocking decisions.
Version and legal transparency
Version 1.0 · 12 November 2026 · Sweden/EU. Source control has been carried out with AI assistance using official legal sources and regulatory guidance. No independent legal review, actual register checks, customer due diligence, regulatory contact, export license review, frozen asset handling or sanctions permit has been carried out. The documents must be adapted to the applicable EU legal act, the company's business and the actual parties. A completed document or an empty Excel overview does not provide any legally exonerating conclusion.
