Consolidated Screening List vs Commercial Databases

The US Consolidated Screening List pulls 13 federal export screening lists into one free searchable database at trade.gov. Commercial databases from Descartes, Dow Jones, and Refinitiv aggregate 100-180 lists across multiple jurisdictions — at $3,000 to $100,000+ per year. Most guides frame this as a budget decision. It's not. The real question is whether your supply chain lives entirely inside US restrictions or whether you've got multi-jurisdictional exposure that makes the CSL's gaps dangerous.

Key Takeaways

• CSL covers 13 US government lists totaling roughly 12,000 entries; commercial databases pull 100-180 global lists (ITA documentation, vendor specs, 2025)
• CSL refreshes within 24 hours of Federal Register publication; commercial database lag runs 4 hours to 7 days depending on provider
• 847 EU-only designations have zero OFAC equivalent — CSL misses all of them (EUR-Lex, European Commission, December 2025)
• Commercial screening runs $3,000/year for basic access up to $20,000+ for 50,000 annual entity screenings (Descartes Visual Compliance benchmark, 2025)
• CSL offers no false positive management — every single hit needs manual verification against source lists

What Does the Consolidated Screening List Actually Include?

The CSL consolidates 13 US government screening lists into one interface (trade.gov, 2025). Full roster: OFAC Specially Designated Nationals, OFAC Consolidated Non-SDN Lists including the Sectoral Sanctions Identifications List, Foreign Sanctions Evaders, BIS Entity List, BIS Denied Persons List, BIS Unverified List, State Department AECA Debarred, Directorate of Defense Trade Controls Debarred, DDTC Foreign Denied, Treasury Non-SDN Palestinian Legislative Council, Treasury Non-SDN Menu-Based Sanctions, Treasury CAPTA List, and FBI Seeking Information.

Roughly 12,000 entries across these sources. Sounds like a lot until you actually look at what's missing.

CSL handles US government restrictions. That's it. No EU Consolidated List. No UK OFSI sanctions. No UN Security Council designations beyond what OFAC already folds in. No Australian DFAT. No Canadian SEMA. The whole system assumes your compliance obligations start and stop with US law.

For a 40-person manufacturer shipping industrial components to three Canadian distributors with zero EU banking exposure, that assumption probably holds. Add a German distributor, a Singapore reseller, or a UK payment processor? The CSL's coverage gaps turn into operational risk fast.

What Do Commercial Databases Add?

Commercial providers aggregate the lists CSL ignores. Descartes Visual Compliance claims 100+ government watch lists across 180+ countries. Dow Jones Risk & Compliance advertises 180+ sources plus proprietary adverse media feeds. Refinitiv World-Check covers 240+ sanctioned and watch lists globally.

The EU gap hits transatlantic exporters hardest. EU Consolidated List maintained 9,234 entries as of December 2025 (European Commission). Of those, 847 have no OFAC match — EU-only designations targeting entities the US hasn't touched. If you've got EU banking relationships, EU subsidiaries, EU-origin components, or ship through Rotterdam or Hamburg, those 847 entries create exposure CSL can't catch.

We watched this play out last year with a client's wire transfer getting flagged in Frankfurt. Recipient sat on the EU Consolidated List but had zero OFAC presence. CSL screening came back clean. German bank's screening didn't. Three-day hold, frantic calls, and a compliance review nobody wanted.

Commercial databases also blow out alias coverage. Single CSL entry might show 3-5 name variations — original plus some transliterations. Same entity in Descartes might show 15-20 aliases: original script, romanizations, common misspellings, known trading names, historical identities. More aliases means more matches. Cuts both ways — you catch true positives you'd miss otherwise, but you also burn hours clearing false positives.

OFAC's SDN list throws roughly 3x more false positives than equivalent EU entries because of this alias-heavy structure (industry benchmark data, 2025). Query "Mohammad" against OFAC and you hit dozens of alias matches. Same query against EU? Way fewer hits. Teams screening high volume against commercial databases aggregating both lists need to budget investigation time — it adds up faster than anyone expects.

How Do Update Speeds Compare?

CSL updates track Federal Register publication timing. OFAC designates someone, FR publishes it, CSL refreshes within 24 hours (ITA documentation, 2025). Actually faster than some commercial providers on certain designation types.

The real problem isn't average update speed. It's Friday designations.

OFAC dropped 23 Friday afternoon designations in Q4 2024 (Treasury.gov designation archives). Your compliance team runs batch screening Friday morning, designation hits at 4pm EST, and now you've got a 62-hour window until Monday where records show "cleared" for a sanctioned entity. Weekend shipments? Cross-timezone operations? Continuous logistics flows? That window turns into actual exposure.

Commercial databases with continuous monitoring close that gap. Descartes Visual Compliance runs dynamic monitoring with alerts when screened entity status changes. Dow Jones offers real-time screening against updated lists. Question is whether real-time capability justifies the price jump.

CSL gives you none of that. No alerting. No continuous monitoring. No notification when a previously-cleared entity catches a designation. Screen once, get your result, and that result goes stale the second you close the browser tab.

Coordinated US-EU designations usually sync within 4-24 hours across commercial databases. Independent designations — OFAC moving without EU coordination — can take 14+ days to hit the EU Consolidated List. Screen OFAC-only through CSL and you're fine on US requirements but exposed on EU banking. Multi-jurisdictional screening isn't a nice-to-have for companies with transatlantic business. It's baseline.

What Doesn't Work About the CSL?

No hit resolution workflow. CSL spits back matches against your query string with zero scoring, zero confidence weighting, zero investigation tools. Every hit — including "Mohamed" matching one of hundreds of Mohamed-variant entries — needs manual verification against source lists. You get a match, then you're on your own sorting out whether it's your customer or some completely different Mohamed on another continent.

Teams running 100+ weekly screenings against CSL burn 4-8 hours on hit investigation alone. That time cost hides behind the "free" price tag. At $75/hour fully-loaded compliance staff cost, 6 hours weekly equals $23,400 annually in investigation labor. Suddenly $3,000/year for a commercial database with match scoring doesn't look so expensive.

No batch upload for ongoing monitoring. CSL API exists — documented, accessible, technically functional. But it's built for one-off lookups, not continuous screening of your partner database. Can't upload 500 counterparties and get alerts when any of them catch new designations. Commercial platforms handle batch upload, persistent monitoring, automated alerting when existing relationships change status. CSL doesn't.

No beneficial ownership screening. OFAC 50% rule says you need to screen entities 50% or more owned by sanctioned parties. CSL gives you list entries. Doesn't give you ownership chains. Screen "Acme Trading LLC" against CSL all you want — you still can't tell if Acme Trading is 60% owned by an SDN-listed individual. Commercial platforms like Descartes have ownership screening modules that surface those connections.

No adverse media. Sanctions lists capture designated entities after formal action. They miss entities under investigation, entities with bad press, entities showing early warning signs. Commercial databases pull adverse media feeds flagging emerging risks before official designation. CSL shows where enforcement already landed. Commercial databases show where enforcement might be heading.

When Does the CSL Actually Work?

CSL works for specific operational profiles. US-only exports. Clear end-user statements. Low transaction volume. Single jurisdiction. No EU banking. No UK financing. No transshipment through restricted territories.

25-person machine shop in Ohio shipping replacement parts to three Canadian customers fits that profile. Compliance officer runs manual CSL checks before each shipment, spends 20 minutes investigating any false positives, documents screening in their records, satisfies US obligations. Done.

200-person electronics distributor shipping to 40 countries with EU banking, Singapore warehousing, and UAE transshipment exposure? Doesn't fit at all. CSL-only screening leaves EU coverage gaps, provides zero ongoing monitoring for an 800-entity customer database, and generates investigation workload that scales linearly with transaction volume. Every new customer, every new shipment — more manual work.

Breakpoint isn't company size. It's jurisdictional complexity. 500-person manufacturer with exclusively US operations might run fine on CSL. 50-person trading company with EU, UK, and Singapore exposure needs multi-jurisdictional coverage CSL doesn't offer.

What Does Commercial Screening Actually Cost?

Descartes Visual Compliance benchmarks at $3,000/year for basic single-user access with limited screening volume. Mid-tier supporting 50,000 entity screenings annually runs around $20,000/year. Enterprise deployments with multiple users, ERP integrations, high-volume screening start at $100,000+ (vendor blog pricing benchmarks, 2025).

Dow Jones Risk & Compliance and Refinitiv World-Check target enterprise. Neither publishes SMB-friendly pricing. Implementation takes weeks to months.

SMB-accessible market has newer players. Platforms like Lenzo, BITE Data, and others offer multi-jurisdictional screening at $99-899/month designed for 30-500 employee organizations. Gap between "free CSL" and "$20,000/year Descartes" isn't your only option anymore.

FAQ

Is the Consolidated Screening List really free?

Completely free — no registration, no usage limits, no API fees. ITA maintains it at trade.gov as public resource. Hidden cost shows up in investigation labor. Every hit requires manual verification with no match scoring or workflow tools to help.

How many lists does the CSL actually cover?

Thirteen US government lists: OFAC SDN, OFAC Consolidated Non-SDN, FSE, BIS Entity List, BIS Denied Persons List, BIS Unverified List, State AECA Debarred, DDTC Debarred, DDTC Foreign Denied, Treasury Palestinian Legislative Council, Treasury Menu-Based Sanctions, Treasury CAPTA, and FBI Seeking Information.

Do I still need commercial screening if I use the CSL?

Depends on jurisdictional exposure. US-only operations with low volume can satisfy requirements with CSL plus manual investigation. EU banking relationships, multi-jurisdictional shipments, high screening volume, or continuous monitoring needs push you toward commercial aggregation.

What's the biggest gap in CSL coverage?

EU Consolidated List. 847 EU-only designations have no OFAC equivalent as of December 2025. EU banking relationships, EU subsidiaries, EU-origin content — all create exposure CSL can't address.

How quickly does the CSL update after an OFAC designation?

Within 24 hours of Federal Register publication — faster than some commercial databases for initial capture. Gap shows up in ongoing monitoring. CSL gives no alerts when previously-cleared entities change status.

CSL versus commercial database comes down to supply chain complexity, not headcount. Single-jurisdiction, low-volume, US-centric operations can live within CSL limits. Multi-jurisdictional exposure, high transaction volume, continuous monitoring requirements — those push toward commercial aggregation. Enterprise platforms at $20,000+/year aren't the only path. Newer entrants including Lenzo offer multi-list screening at SMB price points. Real question is whether your compliance workflow fits CSL's design constraints or whether those constraints create gaps you can't afford to leave open.