Sanctioned? Probably not.

Sanctions screening uses fuzzy name-matching that over-catches by design. Common false positives: partial name matches, nationality triggers (Iranian, Russian, North Korean nationals), dual nationality complications, and indirect blockchain transaction chain exposure to sanctioned addresses. Each requires different evidence to resolve.

Our lead partner spent 7+ years investigating sanctions evasion at a European FIU. He understands screening algorithms, non-association evidence requirements, and OFAC/EU regulatory frameworks. We prepare formal non-association declarations.

• Name matching: Your name, date of birth, or other identifiers partially match an entry on the OFAC SDN list, EU sanctions list, UN sanctions list, or a PEP watchlist. Most matches are false positives — common names trigger flags.
• Nationality-based screening: Some nationalities (Iran, North Korea, Syria, Cuba, Crimea) are automatically subject to comprehensive sanctions. Exchanges block accounts from these jurisdictions entirely.
• Address-based screening: Transactions involving addresses previously associated with sanctioned entities are flagged by blockchain analytics.
• PEP designation: Politically Exposed Persons (government officials, senior politicians, military leaders, and their family members/associates) trigger enhanced screening. Being a PEP doesn't mean wrongdoing but requires EDD.
• Adverse media screening: Negative news or adverse media about you or a counterparty can trigger sanctions screening flags.
• List updates: Sanctions lists are updated regularly. An address or individual not previously sanctioned may be added, triggering retroactive flags on existing accounts.

The vast majority of sanctions screening flags are false positives — your name matches a sanctioned individual but you are not that person. Clearing a false positive requires providing comprehensive identity documentation that proves you are not the sanctioned individual: additional government-issued ID, proof of residence in a non-sanctioned jurisdiction, proof of employment history, proof of date of birth (to distinguish from the sanctioned individual with the same name), and a sworn declaration of identity (a formal legal document affirming your identity under oath). Most false positives resolve within 1-2 weeks with proper documentation. However, if the flag is genuine (you are on a sanctions list or connected to a sanctioned entity), the resolution is much more complex — it may require engaging with OFAC (for US sanctions), the relevant EU authority (for EU sanctions), or the UN (for UN sanctions) to seek delisting or a license. Our lead partner Nils Silinevics spent 7+ years at a European FIU investigating sanctions evasion and understands exactly what evidence is needed to clear false positives and how to engage with sanctions authorities for genuine cases.