Sanctions screening for healthcare and life sciences

• Global supply chains: ingredients, components and devices are sourced through many tiers of suppliers in many countries.
• Distributors in restricted markets: medicines and devices often reach end customers through distributors and resellers, some of them in sanctioned jurisdictions.
• Conditional exemptions: humanitarian and medical exemptions exist, but they come with conditions, and relying on one still means knowing the counterparty.
• Research partners abroad: clinical research sites, laboratories and academic partners can be affiliated with designated institutions.
• State-run health systems: in many countries buyers and payers are public bodies, so officials can be politically exposed persons.
• Ownership behind suppliers: a supplier can be unlisted while its owner is designated.

1. 1

   Map the counterparties

   Suppliers, contract manufacturers, distributors, resellers, payers, research partners and service providers, with the companies that own them.

2. 2

   Screen suppliers, distributors and their owners

   Sanctions and PEP screening of each counterparty and its key people, and ownership screening of the companies behind them.

3. 3

   Check before contract and shipment

   Screen before a supplier is onboarded, a distribution agreement is signed or a shipment leaves.

4. 4

   Confirm the exemption

   Where a medical or humanitarian exemption or licence is relied on, check its conditions and record why it applies.

5. 5

   Monitor and record

   Re-screen the supplier and distributor base when lists change, and keep the evidence of every check and decision.

Healthcare organisations are generally not obliged entities under anti-money laundering law. Sanctions law applies to them like everyone else: they may not deal with designated persons or make funds, goods or economic resources available to them, directly or through a distributor.

Sanctions are applied through UN Security Council measures, the EU's restrictive measures, the US programmes administered by OFAC and the UK's financial sanctions administered by OFSI. Many regimes provide exemptions or licences for medicines, medical devices and humanitarian supplies. These usually carry conditions about the goods, the end user and the parties involved, so relying on one still requires knowing who the counterparty is. Under the OFAC 50 Percent Rule, a company owned by blocked persons can be blocked without being named on a list.

In some countries, such as the United States, healthcare organisations also screen staff, practitioners and suppliers against government healthcare exclusion lists. on8.ai screening includes the US HHS-OIG exclusion list, the federal SAM exclusions and many state Medicaid exclusion lists, alongside sanctions and PEP sources.

• Ownership screening: suppliers and distributors looked through to their owners, with ownership rules such as the OFAC 50 Percent Rule applied.
• Batch screening: the whole supplier and distributor master file screened in one run, then kept current.
• Fuzzy matching: supplier names in many languages and spellings, with aliases, matched without flooding reviewers with false positives.
• Adverse media: enforcement, debarment and criminal allegations surfaced in categories, as a separate signal from sanctions.
• Ongoing monitoring: re-screening when lists change, with alerts only on changes.
• Clear scope: know which sanctions and exclusion lists are covered, including which state lists, for the places you operate.
• Data control: control over where counterparty data is processed, and an audit trail of every check.