EU Sanctions Due Diligence
Review the parties, ownership, goods, route and purpose of a transaction, and record the evidence behind your decision. These 25 topics help structure due diligence. Check current official lists and applicable restrictions at the time of review; this is not a live screening service or legal clearance.
25
Reference guides
Resolve material questions before proceeding
Planning the review
Depends on transaction complexity and specialist review
Budget considerations
Reassess when parties, restrictions or transaction details change
Keeping it current
The WHO-WHAT-WHERE-WHY Framework
EU sanctions due diligence follows a structured four-pillar analysis. Each pillar addresses a distinct risk dimension that must be assessed for every counterparty, transaction, or investment.
| Pillar | Focus Area | Key Questions | Common Red Flags |
|---|---|---|---|
| WHO | Counterparty & Ownership | Is the entity or any beneficial owner on an EU sanctions list? Who ultimately controls the counterparty? | Opaque ownership structures, nominee shareholders, links to sanctioned jurisdictions |
| WHAT | Products & Services | Are the goods, technology, or services subject to EU trade restrictions or dual-use controls? | Dual-use technology, military-grade components, encryption software, luxury goods above threshold |
| WHERE | Geographic & Routing Risks | Does the transaction involve sanctioned countries or high-risk jurisdictions? Are routing patterns suspicious? | Transshipment through third countries, unusual payment routing, mismatched shipping documents |
| WHY | Purpose & End-Use | What is the stated end-use? Does it align with the counterparty's business profile and capabilities? | Vague end-use statements, mismatched quantities, military or surveillance applications |
Where auditors look first
The highest-risk EU Sanctions DD controls - the ones auditors probe earliest and where gaps cost the most. Start your assessment here.
Control Categories
This library groups 25 review topics into 6 categories.
Who Needs EU Sanctions DD?
Applicable Regions
Related Frameworks
Organizations pursuing EU Sanctions DD often also work toward these standards.
Start your EU Sanctions DD self-assessment
Work through the EU Sanctions DD assessment, record supporting evidence and review the gaps in your answers.
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