Sanctions screening

Sanctions apply to everyone within a jurisdiction, not only financial institutions. US sanctions bind all US persons, meaning US citizens and permanent residents wherever they are, companies organized in the United States and their foreign branches, and anyone in the United States. EU and UK sanctions similarly apply to their nationals, companies incorporated there, and activity within their territory.

Any business can breach sanctions: an exporter shipping goods, a shipping firm chartering a vessel, or a software company accepting a subscription. Even FinCrime Studio would breach sanctions by selling a subscription to a designated person. Financial institutions screen most rigorously because nearly every payment passes through them.