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Checking suppliers against the Consolidated Screening List

The Consolidated Screening List (CSL) puts the export-control and sanctions lists of three US agencies into one file. Screening your suppliers against it is a basic step for any company that ships, buys or pays across borders.

Checked against the official sources on October 31, 2026. General information, not legal advice.

What the CSL covers

The International Trade Administration publishes the CSL at trade.gov. It combines, among others:

  • Treasury (OFAC): the Specially Designated Nationals list and other sanctions lists
  • Commerce (BIS): the Entity List, the Denied Persons List, the Unverified List and the Military End User List
  • State: the AECA Debarred List and the Nonproliferation Sanctions list

The CSL is a screening aid: trade.gov says to check the official publication of the list behind a possible match, and do more due diligence, before acting on it.

These lists are separate from SAM.gov exclusions, and they answer a different question: exclusions concern federal awards, while sanctions and export rules apply to a transaction whether or not any federal money is involved. Our 2026 count shows why SAM.gov can't stand in for them.

What the list won't show: ownership

A clean name search doesn't finish the job. Under OFAC's 50 Percent Rule, an entity owned 50 percent or more in the aggregate, directly or indirectly, by blocked persons is itself treated as blocked, even if its own name appears on no list.

So for a higher-risk supplier, ask who owns it. Watch's supplier portal can collect an ownership declaration, and a watch can screen a supplier's owners and parents named in its SAM.gov record ("Watch Acme Corp and its owners for sanctions"). Neither is a full ownership investigation, and SAM.gov's owner fields stop at the immediate and highest-level owner.

Why a match is only ever possible

The lists identify parties by name, aliases and addresses, not by UEI. A supplier whose name resembles a listed party may be a different company entirely. Every name match needs a person to compare the details and decide, and that decision should be recorded so the same false match doesn't come back every week.

How to clear a possible match

  • Compare the full name, aliases, addresses and any identifiers against what you hold on the supplier
  • Open the official list behind the entry, not only the CSL copy
  • Ask the supplier if the details don't settle it
  • Write down who decided, when, on what evidence

If you can't rule it out, stop and escalate before you ship, buy or pay. For a likely OFAC match, OFAC publishes guidance on what to do, and a true match is a matter for your compliance lead and counsel.

How Watch does it

Watch loads the CSL daily from trade.gov and screens each confirmed supplier's legal name and DBA on every check, and again within about 15 minutes when the list changes. A resemblance is shown as "possible screening-list match, confirm", with the list and the score. "This is them" makes it critical and keeps it so; "not them" dismisses that entry for that supplier on future checks. Both are recorded with the person and the time, and with the two-person rule on, a confirmation waits for a second reviewer.

Watch screens entities only; it doesn't screen individuals, vessels or aircraft, and it doesn't classify goods or decide license requirements.

Sources

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Questions

Does the CSL include the OFAC SDN list?
Yes. The CSL combines lists from Treasury (including the OFAC SDN list), Commerce (BIS) and State in one file published by the International Trade Administration.
Is a name match on the CSL a sanctions hit?
Not until a person confirms it. The lists match on names, so a similar name may be another party. Watch shows it as a possible match for someone to decide, and records the decision.
What is OFAC's 50 Percent Rule?
An entity owned 50 percent or more in the aggregate, directly or indirectly, by blocked persons is treated as blocked, even if it isn't named on a list. A name search alone won't show that.
Is the Consolidated Screening List the same as SAM.gov exclusions?
No. SAM.gov exclusions concern eligibility for federal awards. The CSL combines export-control and sanctions lists that apply to transactions whether or not federal money is involved. Screen both.
How often does Watch screen?
On every check (daily by default) and within about 15 minutes of a change to the list, which Watch loads daily from trade.gov.

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