Russia Sanctions Screening: How to Check Companies and Individuals Under the Russia Programs

Not All of Russia Is Sanctioned

There is no blanket US ban on doing business with Russian companies or citizens. Sanctions attach to specific listed parties, specific sectors, and specific activities, not to the country as a whole. Before you can answer "is this company sanctioned," figure out which of three buckets it falls into.

• Full blocking (SDN list). A company or person on the Specially Designated Nationals list is off-limits, full stop. Assets are frozen and US persons generally cannot transact with them at all. Most of Russia's largest state banks, including VTB Bank (fully blocked in 2022) and Sberbank (added to the SDN list in 2023), sit on the SDN list and remain there.
• Sectoral sanctions (SSI list). A narrower category: the company can still be dealt with, but certain transaction types are prohibited, mainly new debt and equity financing above set maturities, under Directives 1 through 4 issued pursuant to Executive Order 13662. It bars specific financing activity, not the company's assets or its goods.
• Unsanctioned. Most Russian companies, including plenty of exporters, manufacturers, and regional banks, appear on no US sanctions list at all. Dealing with them is not automatically illegal, though it may be commercially inadvisable or restricted by export controls outside OFAC's jurisdiction.

So: are all Russian banks sanctioned? No, but most systemically important ones are, either as SDNs or under SSI debt/equity restrictions, and correspondent-banking sanctions under E.O. 14114 let OFAC target foreign banks that process significant transactions for Russia's military-industrial base. Check the specific institution rather than assuming either way.

Which Russia Programs Apply

Russia-related sanctions sit under a stack of executive orders built up since 2014, not one single program. A full embargo, no new investment, trade, or services absent a specific license, covers Crimea (since 2014) and the Russian-occupied Donetsk and Luhansk regions of Ukraine. E.O. 14024, the primary post-2022 authority, is the basis for most current Russia-related SDN designations across finance, defense, technology, and energy.

Separately, OFAC has banned specific categories of services to any person located in Russia regardless of whether that person is listed: accounting, trust and corporate formation, and management consulting were an early wave (2022), with architecture and engineering services added later (2023). These determinations get amended, so confirm current scope before quoting a services engagement touching Russia. The upshot: a clean SDN/SSI result on a counterparty does not automatically clear the transaction. Check whether the location or service type is separately restricted.

Why the 50% Rule Is Make-or-Break for Russia

OFAC's ownership rule treats a company as blocked if it is owned 50% or more, in aggregate, by one or more blocked parties, even if it never appears on any list by name. This matters more in Russia screening than almost anywhere else, because Russia's economy is unusually concentrated around a small number of sanctioned oligarchs and state entities who hold stakes across subsidiaries and shell structures worldwide, not just inside Russia.

A holding company in Cyprus or a trading arm in Dubai can be legally blocked property under the 50% rule despite never being individually designated. Name-only screening will never catch this; it requires tracing beneficial ownership through the corporate structure to see whether a sanctioned party's aggregate stake crosses the threshold. "Not on the SDN list" is not the same as "clear." See understanding the OFAC SDN list for how the 50% rule works and how to document an ownership determination.

US vs. EU vs. UK Sanctions Diverge

The US, EU, and UK each run independent Russia sanctions programs that do not mirror each other. A company can be clean under OFAC and separately listed by the EU's Financial Sanctions Files or the UK's OFSI consolidated list, or vice versa, since the three regimes have different designation criteria and effective dates.

If your business has any cross-border exposure, screening against OFAC's lists alone leaves a real gap. See screening beyond OFAC's own lists for why multi-list coverage matters. OFACScreen's free search checks 8 lists in one pass, OFAC's SDN and Non-SDN Consolidated lists alongside UK OFSI, EU FSF, UN Consolidated, Canada SEMA, Switzerland SECO, and BIS Denied Persons, so one query surfaces a UK- or EU-only hit an OFAC-only tool would miss.

Transliteration Pitfalls: Cyrillic Names

Russian names are written in Cyrillic and get romanized into Latin script inconsistently. Aleksandr, Alexander, and Aleksander are all valid renderings of the same first name. A surname ending in -ов can appear as -ov or the older -off. Patronymics get dropped, abbreviated, or reordered depending on the transliteration standard a database used.

This is why exact-string search fails routinely on Russian names: a search for "Alexander Petrov" will miss a list entry filed as "Aleksandr Petrov." Fuzzy matching, tuned to catch spelling and transliteration variance without burying you in noise, is not optional for Russia screening the way it might be elsewhere. See how fuzzy matching works in sanctions screening for the mechanics.

Step-by-Step: How to Check a Russian Company or Individual

1. Run the entity itself. Search the full legal name through a tool covering all 8 major lists, not OFAC's alone. The free search at ofacscreen.com/screen does this with no signup and returns full results.
2. Search known owners and directors separately. Given the 50% rule, screening the company alone is not enough. Pull the ownership chain and run each owner through the same search.
3. Review program tags on any hit. A tag tied to E.O. 14024 or the Ukraine-EO13662 directives tells you which authority applies and whether it is a full block or a sectoral restriction. Read what it actually prohibits.
4. Verify identifiers such as registration number, jurisdiction, and date of birth against the list entry before ruling on a match.
5. Check for embargoed-region or services-ban exposure even on a clean name search, since those restrictions apply by location and activity, not by name.
6. Document it. The one-time $9.99 audit-ready PDF report packages a single search into a timestamped record with list version dates, ready to hand to an examiner.

Diversion Red Flags: Third-Country Intermediaries

Goods and payments that cannot move directly to or from Russia increasingly get rerouted through intermediaries instead. Armenia, Georgia, Kazakhstan, Turkey, and the UAE have all been flagged repeatedly by OFAC and the Commerce Department's Bureau of Industry and Security as common transshipment points, where a buyer reroutes dual-use goods onward into Russia after the fact. Joint OFAC/BIS guidance has made pursuing this evasion pattern an active enforcement priority.

Red flags: a new counterparty in one of these jurisdictions ordering goods with no clear local end-use, a shipping address that does not match the buyer's business, reluctance to name the end user, or a corporate structure that traces back to Russian ownership on closer look. None of these show up in a name-only screen; they require basic know-your-customer diligence layered on top.

Wind-Down Periods and General Licenses

A new designation does not always mean every existing contract has to stop the same day. OFAC frequently pairs a new SDN listing with a time-limited General License authorizing wind-down of pre-existing transactions, typically 30 to 60 days. Separate standing general licenses cover carve-outs that continue indefinitely, such as certain agricultural, medical, and telecommunications transactions.

Before walking away from a counterparty that turns up a hit, or proceeding on the assumption a relationship is fine, check OFAC's Recent Actions and the Russia-related general licenses page for one that fits. If the hit is a genuine match with no applicable license, see how to handle an OFAC match for the freeze-and-report process.

Bottom Line

The mistake that gets US businesses in trouble is treating "not on the SDN list" as "clear." A Cyprus holding company blocked under the 50% rule, an EU-only designation, a Cyrillic name that never string-matched, a services engagement banned by location rather than by name: none of those surface in a quick SDN lookup, and any one of them can turn a routine deal into a violation. Screen the owners, cover the non-US lists, and check for embargo or services-ban exposure before you conclude a Russian counterparty is safe to deal with.