Sanctions Screening Guidance

The Guidance was published in Jan 2019 and highlights:

• whilst sanctions screening is a primary control, it is not foolproof and needs to be deployed as part of an effective wider sanctions compliance programme; and

• where a risk based approach may be appropriate, including documenting a reasonable risk appetite, notwithstanding the strict liability nature of sanctions compliance.

Consideration has been given to topics such as what is meant by sanctions screening, looking at both reference/customer data and transaction screening; the timing of screening; technology and the use of automated systems; the criteria for alert investigation, as well as testing and quality assurance. The guidance covers a number of areas that are most common to sanctions screening, including: the following:

  • the programmatic approach to sanctions screening is explored, including how to employ a risk based approach.
  • the generation of productive alerts and the use of technology, as well as the importance of testing and validation of the results
  • the approaches to the two main elements of sanctions screening, namely, reference/customer data and transactions screening.

In bringing together the guidance, the Wolfsberg Group noted a number of patterns:

  • the use of regulatory and intelligence lists is explored, along with the management of weak aliases. finally, consideration is given to the importance of a historical review or ‘look back’.
  • there is a heightened increase in regulators’ mandate for the screening of domestic payments, which is more challenging than ever with innovation in technology and increased consumer expectation for instant settlement
  • the increasing complexity of managing sectoral sanctions.
  • a general interest from FI’s and regulators in the opportunities created by an industry utility.

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