Does the undertaking verify its relationships against applicable sanctions lists?

Sanctions list screening is established as part of client due diligence

Yes, in most cases this asks whether the enterprise screens its relationships — customers, suppliers, intermediaries, ultimate beneficial owners — against current sanctions lists, such as those of the EU, the UN and OFAC. This is a question that frequently appears with clients in the financial sector or with buyers who themselves have a Wwft obligation and pass that obligation through the supply chain. The answer "yes" can only be substantiated if a functioning screening procedure exists: a tool or service that matches relationships against the current lists, with a documented frequency (upon establishment of the relationship, and periodically or upon changes to the lists).

An enterprise without a Wwft obligation itself sometimes receives this question anyway, because the buyer wants to demonstrate its own obligation to the supervisor or bank. In that case, the answer is often "no" or "partial" — for example only a manual check for new large customers, without periodic rescreening. There is no problem in reporting that; it only becomes a problem if "yes" is answered without supporting documentation, such as a screening report or an internal procedure description. This question often appears in the same questionnaire as the policy against bribery and corruption, because both fall under the broader theme of integrity and compliance — it is therefore efficient to answer them together.

Where this follows from the Wwft

This question is substantively equivalent to the client due diligence obligation under the Act on the prevention of money laundering and the financing of terrorism. Institutions falling under this act must identify and monitor their clients, and that includes screening against sanctions lists as part of risk-based due diligence. An enterprise that is not itself Wwft-obligated cannot derive this obligation directly from the law, but often receives the question because the buyer — who is subject to the law — must demonstrate that it monitors its own relationships, including suppliers. Those wishing to provide more evidence here may also look at the internal whistleblower reporting channel, as that is often tested in combination in the same compliance policy question blocks.