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Watchlists and sanctions: what they are and how to check

Watchlists and sanctions are legal instruments that governments and international bodies use to restrict relationships with designated people and entities, for reasons of security, foreign policy or the prevention of financial crime. Checking them (what is called screening) is a basic control that institutions apply when onboarding customers and when processing operations.

What financial sanctions are and why they exist

Financial sanctions are measures (such as asset freezing or the prohibition of operations) imposed on specific people, organizations or countries by decision of the authorities. They serve foreign policy, defense and security objectives and the maintenance of peace: curbing terrorist financing, responding to human rights violations and combating corruption. They usually have two natures: targeted ones, which reach individually listed targets, and sectoral ones, which restrict entire economic sectors or governments.

Main international lists (OFAC, UN, European Union, United Kingdom, Canada, Australia)

United States export control (BIS and DDTC)

Part of the U.S. restrictions do not come from financial sanctions, but from export control: rules that limit to whom the U.S. allows the export of sensitive goods, technology and services. Two agencies publish lists of restricted parties:

INTERPOL: Red Notice and Yellow Notice, the difference matters

INTERPOL publishes notices for police cooperation, and telling the types apart matters. The Red Notice is an international request to locate and provisionally detain a person wanted by justice, it is a cooperation request, not a conviction. The Yellow Notice helps locate missing people or identify those who cannot identify themselves, often victims. Treating both the same way would penalize vulnerable people; that is why the distinction is part of the control.

National restrictions and penalties (CGU, TCU, CNJ)

In Brazil, in addition to international sanctions, there are public registers of people and companies penalized by the public administration. Monitoring cross-checks registers maintained by the Office of the Comptroller General (CGU), the Federal Court of Accounts (TCU) and the National Council of Justice (CNJ):

The legal basis includes the Anti-Corruption Law (Law 12,846/2013) and the rules on public procurement and administrative contracts.

Sectoral regulators (Central Bank, ANEEL, ANP, ANS, BCU/SSF, SSN, Federal Reserve, OCC)

Beyond the general public-administration registers, regulators of specific sectors publish their own penalties and restrictions. They are relevant references when assessing counterparties operating in regulated sectors, such as financial services, electricity, oil and gas, and private healthcare:

Capital-markets regulators (CVM and international regulators)

Securities regulators apply penalties to intermediaries, administrators and issuers, and issue alerts about unauthorized operators. They are relevant risk signals when assessing counterparties linked to the financial and capital markets:

Official South American sources (Argentina, Chile, Colombia, Paraguay, Peru and Uruguay)

Beyond the global lists, Orvyan incorporates public sources from neighboring countries, useful when the counterparty has operations, partners or suppliers in the region. They fall into two distinct natures, weighted differently in risk analysis.

Lists of a restrictive or sanctioning nature:

Official registries, used to confirm identity, standing and licensing, not as evidence of conduct:

The distinction matters: appearing in an official registry is expected of anyone operating normally and is not a risk signal in itself. Presence in the first group, by contrast, is a signal that calls for analysis.

Slave-like labor

Part of the lists deals with violations of fundamental rights, not financial crime. In Brazil, the “Dirty List” of Slave Labor, maintained by the Ministry of Labour and Employment, brings together employers caught subjecting workers to conditions analogous to slavery. It is a relevant reference of reputational and labor-compliance risk when assessing partners, suppliers and counterparties. Alongside it is the Conduct Adjustment Registry (CEAC), which lists employers that signed a conduct adjustment agreement to remedy violations related to these conditions.

Human rights, ethical exclusions and forced labor (NBIM, UFLPA)

Internationally, Norway's sovereign wealth fund, managed by NBIM (Norges Bank Investment Management), publishes ethical exclusions: companies the fund decides not to invest in due to involvement with serious human rights violations, severe environmental damage or other conduct contrary to its guidelines. It is not a legal sanction, but a public, carefully reasoned signal of environmental, social and reputational risk, useful in counterparty due diligence.

Also in the human-rights field, the United States maintains, under the UFLPA (Uyghur Forced Labor Prevention Act), a list of entities associated with forced labor in supply chains. Being on this list brings concrete restrictions on goods entering the country and is a forced-labor risk signal when assessing suppliers and counterparties.

Debarment by multilateral organizations

Development banks maintain lists of companies and people barred from taking part in the projects they finance, generally for fraud, corruption or collusive practices established in their own proceedings. The World Bank publishes the list of debarred firms and individuals, and the IDB (Inter-American Development Bank) maintains equivalent sanctions. Unlike the ethical exclusions above, debarment originates in established conduct (fraud/corruption); each plays a distinct role in risk assessment.

US federal debarment (LEIE and SAM.gov)

The U.S. government maintains its own equivalent to Brazil's CEIS: registers of people and companies barred from taking part in federal programs and contracts.

How to check and the challenge of keeping everything up to date

In practice, the query is direct: you provide the person's or company's data (name or tax ID) and the system compares it against the designation lists, returning the matches found. The difficulty is in the details: the same name may appear with different spellings, abbreviations, translations or nicknames, so the matching uses approximate comparison (not just identical text) to avoid missing a real match, without raising too many alerts over a mere name coincidence. Added to this is the ongoing work of keeping the lists up to date: incorporating new designations and removing revoked ones, without lag.

How Orvyan supports

Orvyan cross-checks more than 200 lists and sanction programs, with coverage across more than 30 jurisdictions, in a single query (by name or tax ID) and returns the result classified by risk: HIGH, MEDIUM, LOW or CLEAR, with the detail of each match. Its role is supporting: it recommends and flags the risk, but the decision is always the institution's.

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Frequently asked questions

Do I need to check the national and international lists separately?

No. Orvyan cross-checks more than 200 lists and sanction programs, with coverage across more than 30 jurisdictions, in a single query, by name or tax ID.

What is a false positive and why does it happen?

It is when the system flags a similarity between the person queried and a list record, but the analysis concludes it is not the same person or entity. It can happen due to common names, abbreviations, spelling variations and namesakes.

Does a high-risk result mean rejecting the customer?

No. Orvyan classifies the risk and details each match; the decision to approve, review or reject is always the institution's, according to its policy.

Does Orvyan check lists from other South American countries?

Yes. Beyond the global lists, Orvyan checks official sources from Argentina, Chile, Colombia, Paraguay, Peru and Uruguay, including politically exposed persons (PEP) lists from Colombia and Uruguay, and capital-markets regulators from Peru and Panama. It matters when the counterparty has operations, partners or suppliers in the region.

Is appearing in an official registry, such as Paraguay's taxpayer register, a risk signal?

No. Some of the sources are registries: they serve to confirm identity, standing and licensing. Appearing in them is expected of anyone operating normally. The risk signal comes from the restrictive lists, and the query result keeps the two apart.

What is a leniency agreement and why does it show up in screening?

It is an agreement in which a company admits to having taken part in wrongdoing, such as corruption or bid rigging, and cooperates with the investigation in exchange for reduced penalties. It is the corporate version of a plea bargain. In Brazil, these agreements are signed under the Anti-Corruption Law, with the CGU. Being on this list is not a ban on contracting, the agreement generally avoids that, but it indicates a history of established misconduct, a relevant reputational and compliance risk signal when assessing partners and counterparties. Orvyan flags the match; the decision is always the institution's.