What happens to third-party due diligence if ‘sanctioned’ becomes something fluid?

A temporary sanctions waiver on Russian oil is testing the limits of traditional compliance screening

Something is happening in global energy markets that should make every compliance team sit up and take notice.

The US Treasury has issued a temporary sanctions waiver on Russian oil and petroleum already loaded on vessels at sea, as a short term measure, aimed at stabilising global energy markets during the US-Israel-Iran conflict. The waiver is set to last until 11 April 2026. This is a new kind of sanctions move, and it has not escaped global scrutiny.

Whatever one may make of the decision, a pressing question for compliance professionals is what it signals about the direction of travel — is this where we’re headed? Are sanctions becoming more fluid, more situational, more likely to be turned on and off in response to fast-moving geopolitical and economic pressures? Even if the answer is ‘possibly’, it has real consequences for how businesses approach third-party due diligence.

The limits of aggregator databases in a fluid sanctions environment

The current model for sanctions checking relies heavily on aggregator databases. These are structured lists, updated when a name is added to or removed from a sanctions regime. The model works well when the sanctions landscape is relatively stable (i.e. an entity sanctioned today is expected to remain sanctioned tomorrow, and the database reflects that) but it wasn’t designed for a world in which sanctions status might shift back and forth within days.

Aggregator databases tell you whether an individual, organisation or entity is on a list as of 24 hours ago. Some of the larger providers do retain historical sanctions data, but even that is becoming legally contested. Recent high court cases have argued that retaining historical sanctions inclusion on databases breaches the UK Data Protection Act’s requirements for data to be reliable, timely, up to date and correct. What none of these databases typically capture is the surrounding context: that a sanction was temporarily lifted, or that it might be reimposed next week depending on how talks in the Gulf go.

That’s the kind of context that doesn’t typically live in a structured data field. Additionally, the time lag isn’t trivial. When a sanctions change happens, it typically takes database providers 24 hours to reflect it.

Sanctions alerts can be fast, but manual research is slow

When a change hits, compliance officers do receive an email alert. But in many organisations, the next step is a manual process: checking the updated list against the entire client book to identify any exposure. That work can take days, and critically, it often lacks a clear audit trail. In a world where a company’s or individual’s sanctions status could shift within the same week — or, in a temporary-waiver scenario, even within days and hours — that’s a meaningful gap.

When ‘clean’ doesn’t mean clear

There’s also a subtler risk. If a third party was sanctioned and then temporarily unsanctioned, how that history appears depends on which provider you use. Some screening providers will simply show the entity as clean, with no indication of what came before.

Knowing that a business relationship has recently had sanctions exposure, even temporarily, is crucial context for any risk assessment. It’s the kind of thing that changes how you’d approach a new contract or an ongoing partnership. This is where the distinction between structured data and unstructured context really matters.

Why unstructured data changes the picture

Xapien reads across the open web in over 200 languages, including Farsi and Arabic, including news sources, regulatory filings, court records, and more, and synthesises all the information gathered into a coherent narrative. So when a sanction is lifted temporarily, or when one jurisdiction’s list diverges from another’s (US, UK, UN and EU sanctions lists are rarely aligned, and they’re updated on different timelines and different timezones), that nuance surfaces in the report rather than getting lost.

The cost of re-screening in an unpredictable sanctions landscape

There’s a practical business cost to this too. If sanctions become more unpredictable, compliance teams will need to revisit existing third-party relationships more frequently, not just screen new ones. Every analyst hour spent re-checking an existing relationship is an hour not spent progressing new business. For companies without large in-house compliance teams, or without analysts who have the regional expertise and foreign language skills to cover jurisdictions like Russia or the Middle East, that strain becomes acute fast.

Xapien gives compliance teams the context that structured databases miss. Our platform reads across the open web, surfacing sanctions exposure, temporary waivers, and cross-jurisdictional discrepancies — all fully sourced, so your team can act on the full picture rather than a snapshot. With Xapien, organisations can stay ahead of a shifting sanctions landscape without scaling their analyst headcount. Discover due diligence, uncompromised.