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EU Sanctions DDxlsx

EU Sanctions Due Diligence Checklist (2026 Edition)

Screen counterparties, beneficial owners, goods, routes, and end use with a structured 2026 due diligence checklist. Start the full assessment online or download the XLSX.

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What's Inside

25 risk-weighted due diligence questions across 6 sections with direct regulation links
WHO section - counterparty screening against EU Consolidated List, UBO verification, 50% ownership test, shell company detection, SOE exposure analysis
WHAT section - restricted goods and dual-use technology checks against Annexes to Regulation 833/2014 and Regulation 2021/821
WHERE section - sanctioned territory exposure, circumvention hub analysis (UAE, Turkey, Central Asia), trade routing red flags
WHY section - end-use verification, no-re-export clauses, geographic mismatch detection, business rationale assessment
Reporting obligations - mandatory 2-week reporting under Regulation 269/2014, internal escalation procedures, non-EU subsidiary compliance
Compliance programme evaluation - designated officer, risk assessment, ongoing screening, staff training requirements
Gate questions that flag critical blockers requiring immediate escalation
Risk-weighted scoring with automatic calculation of overall sanctions exposure

About This Template

Every question maps directly to current EU regulation. The template references the EU Consolidated Sanctions List, Regulation 833/2014 (restrictive measures on Russia), Regulation 269/2014 (asset freezing), the Dual-Use Regulation 2021/821, Directive 2024/1226 (criminal sanctions for violations), updated EU Best Practices (July 2024), and the latest EBA Guidelines on restrictive measures (November 2024). Each question includes direct links to the relevant regulation so you can verify the legal basis yourself.

Designed for companies conducting M&A due diligence, onboarding new counterparties, or performing periodic self-assessments against EU sanctions requirements. The checklist uses a risk-weighted scoring system with gate questions (automatic fail on critical findings) and qualifying questions (weighted by severity) to produce a clear pass/fail assessment with a detailed risk breakdown.

Who It's For

Compliance officers conducting counterparty sanctions screening and periodic reviewsM&A teams performing sanctions due diligence on acquisition targetsFinancial institutions assessing client and transaction sanctions riskExport control managers verifying goods and technology against EU restricted listsLegal teams advising on EU restrictive measures compliancePrivate equity firms evaluating portfolio company sanctions exposure

How It Works

1

Open the assessment

Start the EU Sanctions DD checklist in AuditFront. No account is required.

2

Answer and see gaps

Work through each question and see your score, findings, and priorities.

3

Keep it when useful

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Frequently Asked Questions

How often should we run this due diligence checklist?
At minimum: once during counterparty onboarding, then again whenever the EU Consolidated List is updated (which happens frequently - sometimes multiple times per month). For ongoing business relationships, a full reassessment at least quarterly is considered best practice per the EBA Guidelines. High-risk counterparties (those in or near sanctioned jurisdictions, or in sensitive sectors) should be reassessed more frequently.
Does this cover US (OFAC) sanctions as well?
This checklist is specifically designed for EU sanctions regulations. While there is significant overlap between EU and US sanctions programmes (particularly regarding Russia), OFAC has its own designation lists, secondary sanctions provisions, and enforcement approach. If your company has US nexus (US persons, US-origin goods, USD transactions), you need a separate OFAC compliance process in addition to this EU-focused checklist.
What happens if a gate question fails?
Gate questions represent critical compliance requirements. If a gate question fails - for example, a counterparty appears on the EU Consolidated List - the assessment should stop immediately and be escalated to your compliance officer and legal team. Depending on the finding, you may be legally required to file a report with your national competent authority within two weeks under Regulation 269/2014, Article 8. Since Directive 2024/1226, failure to report is a criminal offense in all EU member states.
Is this template suitable for non-EU companies?
Yes, if your company does business with EU counterparties, handles EU-origin goods, or has EU subsidiaries. EU sanctions have extraterritorial reach - the anti-circumvention provisions specifically target arrangements designed to route transactions around EU restrictions. Non-EU subsidiaries of EU parent companies are also subject to a 'best efforts' obligation to comply, as detailed in the EU Best Practices guidance (July 2024).

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