The review thesis
A public-list check is only one part of the answer
Ownership and control, the subject matter, destination, payment route and contractual response can change the sanctions position even where no direct party appears on a public list.
Layered analysis
Why public-list screening is only the beginning
The layers show why ownership, subject matter, payment and contract design can change the answer even when no direct party is listed.
Names
The direct parties and connected persons.
Ownership and control
Direct, indirect and practical control.
Subject matter
Goods, services, technology, destination and use.
Payment
Banks, intermediaries, currency and documents.
Contract
Evidence, notice and a lawful response to restrictions.