Instant sanctions data for confident compliance

The EU’s Instant Payments Regulation (in force since April 2024) requires PSPs, including banks and licensed payment and e-money institutions, to maintain continuous sanctions compliance without delaying instant euro transactions.

• Daily screening: PSPs must check their full customer base against EU sanctions lists at least once per day.
• Immediate updates: Re-screening is required promptly upon publication of new or amended restrictive measures in the EU's Official Journal.
• No transaction-time checks: Instant euro payments (executed within 10 seconds) are exempt from real-time sanctions screening and instead rely on timely customer-level monitoring.

These measures aim to keep instant payments fast while ensuring sanctions compliance remains effective.

This summary reflects the regulatory position as of October 2025 and is provided for informational purposes only; it does not constitute legal advice.

The Official Journal (OJ) is the EU’s legal source of record; new restrictive measures take effect once they are published there.

The Financial Sanctions Database (FSD), maintained by the European Commission, is a consolidated list of sanctioned persons, groups, and entities. It is designed for usability and automation but may lag behind the OJ, as updates appear there only after publication in the OJ.

This reflects the general understanding of the relationship between the OJ and FSD and is provided for informational purposes only.

Delays in sanctions updates can create short-term compliance blind spots.

• Daily screening alone can leave a gap of up to 24 hours between checks.
• Relying only on the Financial Sanctions Database (FSD) can widen that gap, as it is updated only after the Official Journal publishes new measures.

Together, these delays can mean a newly sanctioned person or entity is not flagged immediately.

This reflects general compliance considerations and is provided for informational purposes only.

Many PSPs and banks are turning to real-time sanctions data sourced directly from the EU’s Official Journal (OJ) and refreshed multiple times per hour.

This approach helps close the compliance gap, reduce exposure to newly listed parties, and strengthen resilience in instant payment and continuous compliance environments.

This reflects common industry practices and is provided for informational purposes only.

Trapets helps financial institutions meet the IPR’s sanctions-screening expectations through real-time data, official sourcing, and automated integration:

• Instant EU Sanctions List: Delivered by ION Analytics and designed for instant payments compliance. Updated every 30 minutes to minimise the blind spot from once-daily checks or delayed FSD updates.
• Official source: Data is drawn directly from the EU’s Official Journal (OJ), the legally binding publication.
• Built-in automation: Trapets Screening automatically re-screens customers whenever sanctions data changes.
• Seamless integration: The sanctions feed connects directly to existing Trapets Screening workflows and APIs, supporting continuous monitoring without added manual steps.

Together, these capabilities help PSPs and banks to comply with the IPR while strengthening overall sanctions resilience.

Beyond instant payments compliance, the Instant EU Sanctions List supports other important compliance and risk management processes:

• AML/KYC integration: Feeds directly into onboarding and ongoing/enhanced due diligence workflows to keep customer risk profiles up to date.
• High-speed transaction environments: Ideal for real-time transactions, e.g., FX, crypto, or securities, where instant checks are essential.
• Third-party risk management: Enables FIs to screen suppliers, partners, and investors to avoid sanctioned relationships.