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ECA compliance checklist: 20 checkpoints from application to claim.

ECA transactions often run for ten years or more. This checklist brings together the checkpoints banks, exporters and ECAs should keep in view across the whole life cycle – as a working tool for your team and a basis for your review.

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How to use the list

5 phases, 20 checkpoints

Work through the points per transaction and phase and record date, source and decision-maker for each. An open point is not a failure – but it should be a conscious, documented decision.

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01 Application

  1. 01
    Buyer identified, beneficial owners established

    Ownership and control structure traced to natural persons and documented.

  2. 02
    All parties screened

    Sanctions, PEP and adverse media for buyer, guarantor, project company, key subcontractors, agents and participating banks.

  3. 03
    Country risk assessed

    Buyer and project country against FATF lists, EU high-risk countries, sanctions regimes and export-control country groups – with source and date.

  4. 04
    Agents and commissions reviewed

    Identity, qualification and services of intermediaries; remuneration in line with market practice and justified; commissions disclosed to the ECA (OECD Recommendation on Bribery).

  5. 05
    Export control of the goods clarified

    Control lists, licensing requirements, end use and country-specific restrictions such as Russia or Iran.

  6. 06
    Environmental and social relevance categorised

    Category A, B or C under the OECD Common Approaches; required documents and studies requested.

02 Cover and contracts

  1. 07
    Cover conditions captured

    The ECA’s obligations and conditions in a register with owners and deadlines.

  2. 08
    Clauses in the contracts

    Sanctions, information and cooperation clauses in loan and supply contracts; for goods in scope, the “no Russia” clause under Art. 12g Regulation (EU) 833/2014.

  3. 09
    Declarations complete

    Anti-bribery and other applicant declarations complete, signed and current.

  4. 10
    Approval documented

    Four-eyes decision with reasons – traceable years later.

03 Disbursement

  1. 11
    Disbursement checked against the cover

    Each drawing against covered goods and services and the evidence presented.

  2. 12
    Payees re-screened

    Lists change daily – screening happens at the time of payment, not just at application.

  3. 13
    Price, quantity and goods plausible

    TBML indicators such as over- or under-invoicing, inconsistent goods descriptions or multiple financing checked and deviations documented.

  4. 14
    Transport route checked where relevant

    Route, transshipment and vessels – including listed vessels and suspicious tracking gaps.

04 Loan life

  1. 15
    Ongoing monitoring in place

    Sanctions and list screening for all parties with a defined escalation path for hits.

  2. 16
    Changes reviewed in advance

    Amendments, changes of party and restructurings checked for compliance and cover consequences before they take effect.

  3. 17
    Duties towards the ECA met

    Notification and information duties met on time and evidenced.

  4. 18
    Environmental and social conditions tracked

    Monitoring reports and conditions from the review followed up.

05 Claim

  1. 19
    Evidence dossier complete

    Every phase documented with date, source and decision-maker – organised the way the ECA will request it.

  2. 20
    Sanctions-related obstacles assessed

    Payment obstacles arising from sanctions legally assessed and agreed with the ECA before acting.

General orientation, as of September 2026. The cover conditions of the relevant ECA, the contract and applicable law prevail; the list does not replace a legal assessment of the individual case.

Have your ECA transaction checked against the list?

In the ECA compliance check we review a planned or running transaction – or your ECA process – point by point and deliver a findings report with prioritised actions.