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EU Sanctions Screening 2026/2027 – Customer, Supplier, Ownership Chain and Business Restriction | Word/PDF/Excel
EU Sanctions Screening 2026/2027 – Customer, Supplier, Ownership Chain and Business Restriction | Word/PDF/Excel
- File format
- DOCX, PDF, XLSX
- Document language
- Five Swedish work templates and Swedish user guide; English user guide for Swedish templates; Excel in Swedish
- Number of files
- 7
Digital download. No physical product is shipped.
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About this template
How does your company screen customers, suppliers, and businesses against EU international sanctions? Document a risk-based check before an order, delivery, payment, or new business relationship. This specialist package helps Swedish importers, exporters, wholesalers, and service companies monitor sanctions list matches, false positives, indirect ownership, effective control, circumvention risk, and business prohibitions.
Legal status: Sweden's Act (2025:327) on International Sanctions has been in effect since 10 June 2025. The prohibitions and exemptions themselves are set out in the EU regulations and other relevant sanctions decisions applicable at any given time. The work templates are therefore a control aid, not an updated list of sanctioned persons or a universal legal approval.
Package Contents
01 Sanctions procedure and risk-based scoping. 02 EU sanctions list – match and false positive protocol. 03 Ownership chain, beneficial owner, and effective control. 04 In-depth circumvention risk review. 05 Business prohibition, regulatory contact, and re-review. 06 Swedish user guide. 07 English User Guide. These seven documents are available in editable Word and searchable PDF formats. 08 Excel evidence register with nine tabs. Total 7 DOCX + 7 PDF + 1 XLSX = 15 customer files.
What the Files Contain
Purpose of the check, counterparty type, geographic risk, exact legal act and version, source update date, decision path for matches, identity matching, indirect and cumulative ownership, control through special rights, high-risk transport route, goods/payment flow, decided prohibition, authorized attestation, possible regulatory contact, and new check. Excel collects internal case ID, status, and protected evidence references – not sensitive raw data.
15 Files Supporting Real-World Decisions
| File | Use Case | Format |
|---|---|---|
| 01 Sanctions Procedure | Risk classification, applicable regime, responsibility, sources, and time of check. | SV Word + PDF |
| 02 Match Protocol | Matching and documentation of a possible match, false positive, or remaining uncertainty. | SV Word + PDF |
| 03 Ownership Chain | Assessment of direct/indirect ownership, beneficial owner, and effective control. | SV Word + PDF |
| 04 Circumvention Risk | In-depth review of rerouted trade flows, new intermediaries, goods, banks, and delivery routes. | SV Word + PDF |
| 05 Business Prohibition | Prohibition decision, internal escalation, possible freezing and disclosure obligations, exemption question, and re-review. | SV Word + PDF |
| 06 Swedish Guide | Work procedures, control scenarios, legal boundaries, and sources. | SV Word + PDF |
| 07 English User Guide | English instructions on how the Swedish work templates are used; no English contract templates. | EN Word + PDF |
| 08 Evidence Register | Nine Excel tabs with status options, case references, open control points, and actions. | SV Excel |
Excel – Nine Tabs with Eight Control Indicators
Overview, Counterparties, List Checks, Ownership Chains, Businesses, Red Flags, Prohibition Decisions, Actions, Read Me. The formulas show registered counterparties, possible list matches, unclear ownership assessments, open business cases, red flags, prohibited decisions, and overdue actions. All indicators have been tested with synthetic examples and then reset to zero.
Important: Zero cases does not mean that any check has been performed. Excel can neither check current EU lists nor make decisions about the legality of a business. Use an authorization-controlled system for identity documents and underlying evidence.
Legal Boundaries
1. The check must be carried out against the current legal act. EU international sanctions regimes have different sets of persons, goods prohibitions, payment prohibitions, ownership/control provisions, and exemptions. Check both the updated EU legal act and the company's role and geographic connection. Official EU Commission sanctions information.
2. A positive match is not automatically the right person. Name similarity and incomplete information should be investigated using appropriate and legally accessible identity data. A false positive result should be documented – not assumed. An investigated match may lead to an immediate internal prohibition and a separate obligations analysis.
3. There is no universal 50-percent exemption rule. Some sanctions regimes contain express rules on ownership and control. Ownership shares must be assessed together with any indirect structure, agreements, and actual decision-making power. The EU Commission's guidance on risk-based due diligence helps with risk identification but is not itself a binding Swedish form.
4. Circumvention risk applies to more than name lists. A changed shipping route, unusual intermediary, new end customer, or payment arrangement may require an in-depth review based on actual goods and transaction prohibitions.
5. Regulatory contact is situation-dependent. Freezing, reporting, exemptions, and possible contact with the Swedish Financial Supervisory Authority, Swedish Trade Board, or other competent authorities depend on the current sanctions regulation and national competence allocation. Check this before a form is submitted.
How to Use the Documents
- Identify the counterparty, business, geographies, and risk level in the procedure template.
- Check the current EU regulation, official list, and source, including the date.
- Investigate any matches with documented evidence and an authorized reviewer.
- Analyze the ownership chain and effective control, even when there is no direct list match.
- Test goods-, service-, route-, and payment-related red flags.
- Decide on a prohibition, completion, or termination with a traceable reference and re-review.
- Follow the case ID and action status in Excel without copying protected personal data.
Frequently Asked Questions
Can the template perform an automatic sanctions screening?
No. It documents an actually performed review. Current official sanctions data must be retrieved and checked separately.
Is a match on the same name always a prohibition?
No. A possible identity match requires investigation and assessment according to the definitions in the legal act.
Is the company approved if no listed person owns 50 percent?
Not automatically. Effective control, indirect ownership, and the scope of the respective prohibition must be analyzed.
Can a Swedish company always continue trading after Excel shows Clear?
No. A status marking does not provide any legal permission or exemption from sanctions.
Do the files contain real sanctions lists?
No. Sanctions lists change continuously and are not included as static customer content.
Are the PDF files fillable?
The PDF files are searchable and printable. Edit in Word and Excel.
Are the same work templates available in English?
Five work templates and Excel are in Swedish. A separate English user guide describes their use.
Version and Review Level
Version 1.0 · November 12, 2026. Jurisdiction: Sweden/EU. AI-assisted check against Act (2025:327), official EU and Swedish government sources. No external legal review, actual counterparty screening, regulatory contact, or certification has been performed. Adapt to the current sanctions regulatory framework and have an authorized lawyer/compliance officer review live cases. The product draft is not published, and the customer ZIP is not linked to Digital Products at this stage.
