Sanction lists: how can your airline stay compliant?

Sanction lists are a key part of many countries’ foreign policy – and airlines play an important role in supporting their implementation. But staying up to date with sanction lists is increasingly challenging for travel operators.

Key takeaways:

The list of sanctioned countries and individuals is growing rapidly
Small and medium airlines in particular are struggling to keep up
Learn about methods for complying with US, UK, UN and EU sanction lists

Picture this common scenario. The ops team at a small European business charter airline are trying their best to comply with international sanction lists. Each time customers book a flight, the team needs to check their names against several, ever-expanding lists of sanctioned individuals. It’s especially challenging because sanctions are applied to people from multiple countries around the world – so every passenger needs to be checked. And it’s also high pressure, mistakenly transporting persons under sanctions could result in big penalties for the airline.

Complying with sanction lists is becoming ever more complex for airlines – particularly smaller carriers who may not have dedicated staff or tools to continually verify all passengers and crews. Although sanctions have existed for decades, they are being used ever more widely today – and their number has grown exponentially since Russia’s invasion of Ukraine in 2022.

Prior to the invasion, there were 2,754 sanctions against Russian individuals and businesses according to Statista. But by early 2023 there were almost 11,500 – with more expected. And it’s not just the Russian sanctions list that airlines need to be aware of. Iran, Syria, Belarus and Myanmar have all seen an uptick in sanctioned individuals of late.

So, how can travel operators comply with sanction lists?

What is a sanction list?

Sanctions can be defined as restrictive financial, trade or travel measures imposed against individuals, companies and other entities. They may be adopted by individual states (unilaterally), by several states working together (multilaterally) or internationally at the UN level. Sanctions vary. They may include bans or restrictions on the trade in goods, technologies, and services. They could also include the freezing of funds and other financial sanctions. And they often include travel bans – preventing individuals from crossing borders.

When it comes to the aviation industry, the most important sanction lists to be aware of are those which target individuals. Many sanction lists explicitly prohibit airlines and other transport operators from carrying sanctioned people.

If an airline fails to comply with sanctions, then they face fines, reputational damage, and could even be closed down. And governments enforce these rules strictly. For example, in November 2022, a Maltese airline that transported family members of a Russian citizen who is on the United States’ OFAC Sanction List, had eight of its planes blocked.

Suggested: What is API PNR data?

Challenges of complying with sanction lists for airlines

Complying with sanction lists is mandatory for all airlines, and they must follow the rules in all countries they operate in. This can be challenging for several reasons:

Pace of change: One of the biggest challenges of complying with sanction lists is the sheer pace of change – particularly with regard to Russian sanctions lists. Over the past year, thousands of individuals have been added to lists in waves. Ensuring your airline is up to date with the latest sanctions information from every country you operate in is very difficult.
Time and money: Verifying the identities of travelers against sanction lists adds additional process workload for the operational staff .
Difficult to access information: At present, there is no global, consolidated list of all sanctions imposed by all countries against all individuals. Instead, airlines need to seek out information about sanctions from the authorities in each country where they operate. The lack of a globally consolidated list of sanctions can make compliance a real headache.
Compliance skills: Until fairly recently, the industry most affected by sanctions was the financial services industry. Financial institutions have developed extensive processes for monitoring individuals facing financial sanctions, and have developed extensive Know Your Customer (KYC) processes. However, SMEs in other industries (including aviation) are increasingly being asked to participate in sanctions regimes and identify sanctioned travellers. However, few of these businesses have the legal expertise or resources to conduct sanctions list checks.

Where can your airline find the latest sanction lists?

If your airline is at risk of transporting sanctioned individuals (the risk may be higher if you transport persons with Russian, Belarussian, Iranian or Syrian citizenship – although sanctioned individuals can have any nationality), then it’s important to complete a sanctions list search.

EU sanction list

The EU sanction list can be found here. It comprises multilateral sanctions that must be followed by all EU member states.

US sanctions list

The United States’ sanction list (known as the OFAC Sanctions List) is available here. You can conduct a list search to find the names of all sanctioned individuals who are barred from flying to the US.

UN sanction lists

The United Nations’ Security Council’s sanctions lists are available here.

Other countries’ sanction lists

Many more countries around the world impose sanctions on individuals, businesses and entities from other nations, which are usually available online. Below are some other countries’ sanctions lists:

Three ways airlines can comply with sanction lists

How can your airline comply with these complex and ever changing sanction lists? Broadly speaking, there are three methods available:

1. Conduct manual or semi-automated searches

The most basic method of complying with sanction lists is to conduct manual searches of your destination country’s consolidated lists of sanctions. Typically, an airline employee will be charged with compiling and maintaining a database which must be checked for each passenger and crew carried.

Evidently, there are drawbacks of the manual approach. Creating and maintaining lists is expensive and time consuming, and there is plenty of room for mistakes and human error (e.g., mistyping an individual’s name when searching the list).

2. Subscribe to international sanction list services

As more and more countries use sanctions as part of their foreign policy, several businesses have set up databases where customers can access information on all sanctioned individuals and entities. Companies such as Sanction Scanner, Dow Jones, Moody’s Analytics and LexisNexis provide reliable, comprehensive and up-to-date information.

While these services are valuable, they still have the drawback of being essentially manual. Costing a lot of time for operational staff with the same risk of human error.

3. Use full automated sanction list software

A different solution for airlines is to use an automated, airline-specific sanctions list checker. At Streamlane, our platform, built initially for API PNR, now includes a sanction list search that automatically checks passenger names against the consolidated lists of major countries and blocs (as of June 2023, it includes US sanction lists, EU sanction lists, UK sanction lists and UN sanction lists – with more lists to be added in future).

This solution entirely automates the sanctions compliance process, saving time for your operational staff and protecting your business from related risk.

Use Streamlane to comply with travel sanction lists

At Streamlane, we work closely with multiple Business Aviation carriers as well as Charter airlines – and we fully understand the challenges involved in complying with sanction lists. With our sanction service, we aim to help keep your operations up to date with ever changing sanctions lists, reduce your non-compliance risk, and allow you to focus your time and energy on your core business.