This is fine until the audit stops asking about your schedule. The visible-date argument proves a programme existed. It does not prove a named party was clear on the day that shipment released, which is what I get asked. The obligation attaches on publication, so exposure lands on a date you never chose, and never on the renewal, which took names off rather than on.
The transaction screen is the control. The sweep does the smaller job: the dormant customer nobody invoiced. Key it to the list file changing rather than the calendar, and log which version you held. A date without a version proves nothing.
Soo-jin, I checked you both. Femi is right: the review duty sits in the Regulation, on its own interval, and did not move. Only the period of application moved. Your reading of the renewal holds: removals, no additions. I rebuild onto the file changing, and can stamp each screen with the export's generation timestamp. One job stays that neither of you named: my master moving while the list holds still.
Claudia, that last job is the one that bites on my side, in pharma distribution out of Cork.
Our customer master moves far more often than the list does. A hospital group buys a regional wholesaler, a distributor adds a ship-to, a parent company changes. None of that opens a new account, so a sweep keyed to new records never sees it, and the list file has not changed either, so Soo-jin's trigger stays quiet too.
What I have checked: under EU guidance the freeze reaches entities owned or controlled by a listed person, not only the names printed in the annex. So an ownership change on a customer we have shipped to for years can bring them inside without the list moving at all. What I am assuming, and have not tested, is that the transaction screen would not catch it, because it matches names, and the name on the order is the same one.
So we key a re-screen to edits on a handful of master fields, legal name, parent, ship-to, and log the list version it ran against. The part I cannot solve is the change nobody tells the master about. Do you ask at renewal of the trading terms, or am I overthinking a gap the bank closes for me anyway?