Screening for sanctions and PEPs: what the EU consolidated list covers

"Do we screen for sanctions?" is a question most Irish designated persons can answer with a yes. "Which lists, how often, and who in the firm owns it?" is where the answers get vaguer. Screening is often the least documented part of an otherwise reasonable AML programme: a check gets run at onboarding, a result gets glanced at, and nothing is recorded.

That gap matters more from 10 July 2027, when Regulation (EU) 2024/1624 (AMLR) starts to apply directly to Irish firms. Among other changes, the AMLR requires prescribed compliance roles — and from that date, your compliance officer becomes responsible for the implementation of targeted financial sanctions within the firm. Screening stops being an informal habit and becomes a named person's accountability.

Here is what the EU consolidated sanctions list covers, how it differs from PEP screening, and what your firm should have in place before the AMLR applies.

What the EU consolidated list is — and what it is not

The EU consolidated financial sanctions list is a single reference point for the individuals and entities subject to EU targeted financial sanctions. Instead of tracking dozens of separate sanctions measures, a firm can screen a client name against one consolidated dataset.

Be precise about what a hit against this list means. Targeted financial sanctions are prohibitions. If a client or beneficial owner appears on the list, the issue is not "higher risk" — it is that dealing with them, or making funds or resources available to them, is generally prohibited. That is a fundamentally different outcome from every other check in your customer due diligence process.

Just as important is what the consolidated list does not cover:

• PEPs. Politically exposed persons are not sanctioned persons. They do not appear on the consolidated list, and a clean sanctions result tells you nothing about PEP status.
• High-risk countries. The EU maintains a separate high-risk third-country list. That is a list of jurisdictions, not names — it feeds your risk scoring, not your match screening.
• Other regimes' lists. The EU list is the EU's. UN, US (OFAC) and UK (OFSI) sanctions are separate datasets, and depending on your clients, transactions and currency exposure, your risk assessment may justify screening against them too.

If your current procedure says only "screen against sanctions lists" without naming which lists and why, that is a gap worth closing now.

Sanctions screening and PEP screening are different jobs

The two checks often run through the same tool, which is why they blur together. But they answer different questions and demand different responses.

The practical consequence: your procedures should never treat "screening result: clear" as one tick-box. A sanctions match and a PEP match lead down entirely different paths, and your file should show which check was run, against which lists, on what date, and what decision followed.

What the AMLR changes for Irish firms

Irish firms have carried screening obligations under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 for years. The AMLR does not invent screening — but it changes the frame around it in ways worth noting:

• Named ownership of sanctions. The AMLR prescribes compliance roles: a board-level compliance manager and a compliance officer of sufficiently high standing. From 10 July 2027, the compliance officer is also responsible for the implementation of targeted financial sanctions. Your firm needs to decide who holds that role and record the designation.
• A directly applicable rulebook. As a regulation, the AMLR applies in Ireland without transposition. The institutional layer — supervision and FIU arrangements — is handled separately under Directive (EU) 2024/1640 (AMLD6). Your CJA 2010-era screening procedures will need to be checked against the new rulebook, not just rolled forward.
• New high-wealth EDD triggers. The AMLR introduces enhanced due diligence for high-net-worth relationships involving assets of 5 million euro or more handled for a client whose total wealth is 50 million euro or more. Wealthy clients and PEP-adjacent clients overlap heavily in practice, so PEP screening and these new triggers belong in the same procedure.
• Terminology. Irish law calls you a "designated person"; the AMLR says "obliged entity." Expect to see both.

Your supervisor will ask for evidence, not assurances

Whoever supervises your sector — the PSRA for estate and letting agents, the Law Society of Ireland for solicitors, the designated accountancy bodies (CAI, ACCA, CPA Ireland) for accountants, the AMLCU for TCSPs and high-value goods dealers, or the Central Bank of Ireland for financial firms — the expectation is the same. It is not enough that screening happened. You need to be able to show it.

A defensible screening file for any client answers five questions:

1. Who was screened — the client, and the beneficial owners you identified?
2. Which datasets were checked, and on what date?
3. What did the result say — clear, possible match, or confirmed match?
4. If there was a possible match, who reviewed it, and why was it discounted or escalated?
5. When is the next scheduled re-screen, and what events trigger an earlier one?

A screenshot in a folder answers perhaps one of those. A logged, dated record answers all five.

What to do now

• Write down your list coverage. Name the datasets your firm screens against — EU consolidated list and UN as a baseline, plus OFAC and UK OFSI where your risk assessment justifies them — and record the rationale.
• Separate sanctions and PEP outcomes in your procedure. One path is a hard stop; the other is enhanced due diligence. Make sure staff know the difference.
• Screen beneficial owners, not just the client entity. Your CDD process already identifies owners at the 25 per cent threshold; run them through the same screening.
• Designate your compliance officer now and note their forthcoming responsibility for targeted financial sanctions from 10 July 2027.
• Set a re-screening rhythm. Lists change; a screen from onboarding three years ago proves nothing about today.
• Build the evidence trail. Date-stamped results, reviewer decisions on possible matches, and escalation notes — retained in line with your record-keeping obligations.

Where CompliDesk fits

CompliDesk Ireland is being built for the AMLR from day one, with screening that surfaces the EU consolidated list, UN datasets and PEP results — logged, dated and reviewable, so the evidence trail builds itself. If you want to see how your current screening set-up compares with what the AMLR expects, start with our AMLR explainer.