Table of Contents
A denied party screening SOP is the written procedure your staff follow every time they check a name against sanctions and restricted party lists. It spells out who does what, in what order, and what happens when a match shows up. A good SOP turns screening from guesswork into a repeatable habit. Anyone on the team can pick it up and get the same result.
This guide shows you how to write one. It stays close to the daily work. If you want the broader rules and governance, read our guide to the denied party screening program. This article is about the hands-on steps your people take at their desks.
SOP versus policy: know the difference
A policy says what you do and why. It sets the rules, the scope, and who owns the risk. An SOP says how you do it, step by step. Think of the policy as the map and the SOP as the walking directions.
Keep the two separate. Your policy might state that you screen every customer before shipping. Your SOP tells the shipping clerk which tool to open, what fields to enter, and when to stop and call someone. If you blend them, both get harder to use. Build your rules first, then write the procedure that carries them out.
Define roles and who does what
Start by naming the people. Screening fails when nobody knows who runs the check. List each role and the exact task it owns. Use job titles, not personal names, so the SOP survives staff changes.
| Role | What they do |
|---|---|
| Screener (sales, order entry, or logistics staff) | Runs the check, records the result, flags any hit |
| Reviewer (compliance officer or team lead) | Reviews flagged hits, decides if a match is real |
| Approver (senior manager or compliance head) | Holds or releases the transaction, signs off on true matches |
| Record keeper | Files the screening evidence and keeps the audit trail |
Small teams may combine roles. That is fine. Just make sure one person never both flags and clears the same true match. Keep that split for control. If you outsource part of the work, name the provider and their tasks too. See our note on whether trade compliance can be outsourced.
Write the exact screening steps
This is the heart of the SOP. Write each step so a new hire could follow it without asking. Number the steps. Name the tool. State the fields.
- Collect the party details. Full legal name, any trading names, address, and country.
- Open your screening tool or the government lists you use.
- Enter the name and address. Screen the company and its key people.
- Set a match threshold that catches near spellings without drowning you in noise.
- Read the results. A clean pass means no likely match on any list.
- If a hit appears, do not proceed. Flag it and move to the review step.
- Record the result. Save who screened, when, what lists, and the outcome.
Name the lists you screen against. Most teams check the Consolidated Screening List, the OFAC SDN List, and the BIS Entity List. Add the lists that fit your trade lanes. For the full method, link staff to our guide on how to do denied party screening. Also state your ownership rule. A party can be blocked by owners even if it is not listed itself, so cover the 50 percent rule.
Handle hits and false positives
Most hits are not real. A common name or a shared city can trigger a flag. Your SOP needs a clear way to sort true matches from noise. Write this section carefully. It is where staff freeze if the steps are vague.
- Compare the full name, address, and date details against the list entry.
- Check for owners or parent firms that may be listed.
- Write down why you cleared or held the hit. Keep the reason on file.
- Never clear a hit from memory. Every decision needs a note.
Give staff a tie breaker. When in doubt, hold and escalate. Our guide on false positives in denied party screening shows how to judge a weak match. Train the team to spot sanctions evasion red flags too, since some parties hide behind clean-looking names.
Set escalation and timing
Escalation is the path a hit takes when the screener cannot clear it. Spell out the path and the clock. Staff should know who to call and how fast.
- Screener flags the hit and holds the transaction the same day.
- Reviewer checks the hit within a set window, such as one business day.
- If the reviewer confirms a true match, the approver decides next steps.
- A true match means you stop. Do not ship, pay, or release goods.
- Seek legal advice before any further action on a confirmed party.
State how often you screen, not just at onboarding. Names get added to lists over time. Decide your rescreening rhythm and write it in. Our guide covers how often to run denied party screening. Getting this wrong carries real cost. Remind staff of the penalties for dealing with a denied party.
Build templates and records
Templates save time and keep records consistent. Attach them to the SOP so staff use the same forms every time. Two forms cover most needs.
- A screening log. Party name, lists checked, date, screener, and result.
- A hit review form. The match found, the reason to clear or hold, and the sign-off.
Keep these records for the period your rules require. They prove you screened if a regulator asks. Read our note on what an audit trail should contain. For a quick task list to check your SOP against, use our denied party screening checklist.
Train the team and keep it current
A written SOP only works if people know it. Walk new staff through the steps on day one. Run a short refresher when lists or tools change. Watch someone screen a live order to confirm they follow the procedure.
Review the SOP at least once a year. Update it when your tools, lanes, or lists change. Our guide to effective compliance training can help you plan sessions. Keep the whole thing tied back to your wider denied party screening approach so the procedure and the rules stay in step.
Frequently Asked Questions
How long should a screening SOP be?
Keep it short and usable. A few pages is enough for most teams. Cover roles, steps, hit handling, escalation, records, and training. If a section runs long, move detail into a template or an appendix.
Should the SOP name a tool or stay generic?
Name the tool you use. Staff need to know exactly where to click. If you screen by hand, name the government sites instead. Our comparison of automated versus manual screening can help you decide.
Who should approve the SOP?
Your compliance owner or a senior manager should sign it. Their approval shows the procedure has backing. It also sets who to consult when the SOP needs a change.
Key Takeaways
A denied party screening SOP works when it is plain, specific, and easy to follow. Name the roles, write the exact steps, and set a clear path for hits and escalation. Add templates so records stay consistent, then train the team and review the document each year. Do this well and screening becomes routine, not a scramble. If you want help building your procedure, get in touch with our team.