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.
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.
01 Application
- 01Buyer identified, beneficial owners established
Ownership and control structure traced to natural persons and documented.
- 02All parties screened
Sanctions, PEP and adverse media for buyer, guarantor, project company, key subcontractors, agents and participating banks.
- 03Country risk assessed
Buyer and project country against FATF lists, EU high-risk countries, sanctions regimes and export-control country groups – with source and date.
- 04Agents 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).
- 05Export control of the goods clarified
Control lists, licensing requirements, end use and country-specific restrictions such as Russia or Iran.
- 06Environmental and social relevance categorised
Category A, B or C under the OECD Common Approaches; required documents and studies requested.
02 Cover and contracts
- 07Cover conditions captured
The ECA’s obligations and conditions in a register with owners and deadlines.
- 08Clauses 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.
- 09Declarations complete
Anti-bribery and other applicant declarations complete, signed and current.
- 10Approval documented
Four-eyes decision with reasons – traceable years later.
03 Disbursement
- 11Disbursement checked against the cover
Each drawing against covered goods and services and the evidence presented.
- 12Payees re-screened
Lists change daily – screening happens at the time of payment, not just at application.
- 13Price, quantity and goods plausible
TBML indicators such as over- or under-invoicing, inconsistent goods descriptions or multiple financing checked and deviations documented.
- 14Transport route checked where relevant
Route, transshipment and vessels – including listed vessels and suspicious tracking gaps.
04 Loan life
- 15Ongoing monitoring in place
Sanctions and list screening for all parties with a defined escalation path for hits.
- 16Changes reviewed in advance
Amendments, changes of party and restructurings checked for compliance and cover consequences before they take effect.
- 17Duties towards the ECA met
Notification and information duties met on time and evidenced.
- 18Environmental and social conditions tracked
Monitoring reports and conditions from the review followed up.
05 Claim
- 19Evidence dossier complete
Every phase documented with date, source and decision-maker – organised the way the ECA will request it.
- 20Sanctions-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.
© 2026 Trade Finance Intelligence · https://www.tradefinance-intelligence.com/insights/eca-checklist/ · info@tradefinance-intelligence.com
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.