EU Sanctions Due Diligence Checklist (2026 Edition)

The workbook has three sheets: Due Diligence, Risk Summary and Instructions. Its 25 checks organise an initial review of the parties and transaction. Each entry has an evidence field, a place for rationale and a link to an EU source. The file does not screen names against a live list or establish that a transaction is permitted.

Check the current official lists and restrictions on the date of the review. Resolve ownership and control as well as name matches; a clean name search alone is insufficient. Record which sources were checked, when they were checked and which facts still need confirmation. Revisit the review if a party, route, product or destination changes.

The score helps prioritise questions. It is not legal clearance. A failed critical gate produces a STOP result for escalation, and a low score does not override a prohibition or a licensing requirement. Reporting obligations depend on the applicable restriction and the facts. Refer unresolved issues to the responsible compliance or legal reviewer before the transaction proceeds.

The download is available without an account or email address. Keep a working copy, record who completed the review and retain the evidence used to reach each decision. The online assessment is a separate way to organise your review; downloading this file does not create an assessment in the app.