itsual Sanctions Screening
Overview
Sanctions screening prevents dealings with prohibited parties and jurisdictions. Effective programs combine quality list data, tuned matching, skilled alert disposition, and clear escalation.
When to Use
- Customer and beneficial-owner screening at onboarding and refresh
- Payment and transaction screening
- Counterparty and vendor screening
- Sanctions program design or tuning reviews
Core Practices
- Source and update sanctioned-party lists from authoritative feeds
- Define screening points (onboarding, periodic, before payment)
- Tune matching to balance true hits vs false positives
- Document alert investigation and disposition rationale
- Escalate true matches through defined approval channels
- Restrict or exit relationships when required
- Test controls and maintain audit trails
Principles
- False-negative risk is existential; false-positive floods destroy effectiveness
- List quality and timely updates are foundational
- “Name match” is not automatic guilt — investigation discipline matters
- Governance must cover model/tuning changes to matching logic
Verification
- Screening coverage points are defined and complete
- Alert handling has documented standards and quality checks
- Escalation and blocking paths are tested