What You Need to Know About Best Practices in Sanctions Screening


Sanctions lists are a key source in the effort to stop serious crimes, such as terrorism and money laundering. They change regularly and require consistent monitoring. You are obligated to keep lists up to date and effective or risk heavy penalties for noncompliance. Knowing the best screening practices and implementing them regularly is the first step in maintaining an effective sanctions list. 

Establish a Strong Onboarding Process

Proper sanctions screening starts with the onboarding process. You have a responsibility to vet new customers thoroughly before adding them to the sanctions list. This requires a sophisticated identification process, designed to improve the customer’s profile and collect enough information to confidently assess their sanctions risk. The standard onboarding process includes collecting the name, address, phone number, date of birth, and social security number. However, you can include biometric information, such as voice and face scans or fingerprints, as well. 

Human Analysis of Sanctions

Given the prevalence of the Internet of Things and 5G capability, automation will become increasingly more prominent. It is a powerful and effective tool for data analysis, but A.I. often generates information that can only be effectively assessed with human discretion. Essentially, you cannot rely entirely on technology and automation to do your data analysis. A trained team of humans is invaluable to a productive screening process. 

Check Sanctions Information

Sanctions lists are often obtained by more means than just the onboarding process. You may get entire lists and other data from another institution or a service you hired to collect them. Regardless of how you receive it, you have a responsibility to check the source and the list to ensure that everything is reliable. Beyond that, you need to thoroughly screen the information in the lists to ensure that nothing has been modified; sanctions lists are typically easily edited. 

Avoid Misidentification

Unfortunately, misidentification does happen. Sometimes a name on the sanctions list does not contain enough information to create a unique profile. When this happens, you can receive a false positive. The best way to avoid this issue is to create a screening process that involves a minimum of three identity confirmations. For example, ask for a name, address, and social security number. If you do not have all three on file, you can ask for another unique identifier, such as passport number. If you do not have enough information to confirm the identity, move on to manual checks.

Check for Periodic Updates

Sanctions are regulated by government and international authorities. To remain up to date, you must consistently monitor announcements from these authorities. You are going to look for changes to sanctions lists and screening requirements. Neglecting this practice could result in penalties for noncompliance. 

Set Up Protocols for Cultural Diversity

Naming arrangements vary culturally and must be considered during your screening process, especially if you have an international customer base. You must account for variations in language characters and screen for potential alternative names. In Arabic-speaking cultures, it is common for a person’s first name to contain a suffix using one of the descriptive names of Allah. For example, the first name Abdul might have the suffix “Rahman” or “Akbar.” These are not to be mistaken for last names.

Keep Customer Information Relevant

In the simplest of terms, you must regularly check your customer profiles for outdated information. Introduce a process during screening that allows you to build on a profile to input more distinguishing information. The more data you collect, the less likely you are to experience false positives and misidentifications. 

Involve your team in the screening process. Keeping several sets of eyes on the lists helps to maintain its reliability. Given the decisive nature of sanctions lists, monitoring them should be a permanent priority.


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