Sanctions Screening

Sanctions screening is a control employed within Financial Institutions (FIs) to detect, prevent, and manage sanctions risk. Screening should be undertaken as part of an effective Financial Crime Compliance (FCC) program, to assist with the identification of sanctioned individuals and organizations, as well as the illegal activity to which FIs may be exposed. It helps identify areas of potential sanctions concern and assists in making appropriately compliant risk decisions.

ComplyGenics assists clients in assessing the effectiveness of their sanctions screening controls, whether automated, manual, or both.

Transaction

Screening

Transaction screening is used to identify transactions involving targeted individuals or entities.

Customer Screening

Customer or Name screening is designed to identify targeted individuals or entities during on-boarding or the lifecycle of the customer relationship with the FI.

Together, transaction and customer screening are designed to form a robust set of controls for identifying sanctions targets. It should be recognized that there are several limitations in the way in which these controls are managed and should always be employed as part of a wider FCC program.

ComplyGenics has deep experience in building and supporting sanctions screening programs and can provide the technology and expertise you need to avoid penalties and stay profitable in this competitive market. ComplyGenics helps in implementing a digital platform for global screening and politically exposed person (PEP) search.

Sanctions Screening & Watch List Filtering

We will work with you to enhance the overall sanction screening program:

Policies & Procedures

defining requirements for what must be screened, in what context and at which frequency, and how alerts should be adjudicated, paying attention to how to resolve alerts where information is unavailable, incomplete, or potentially unreliable.

Risk Assessment

applying risk-based decisions to resolve specific questions of what data attributes to screen, when to screen, what lists to use, and how exact or “fuzzy” to set the screening filter. The decision making and governance structure need to be clearly articulated, documented, and supported by analysis and testing.

Internal Controls

implementing screening control processes requires an understanding of the various methodologies and technologies available and their operational consequences. Financial institutions are expected to document how their screening systems are configured to demonstrate that the set up is reasonably expected to detect and manage the specific sanctions risks.

Testing

validate that the screening system is performing as expected and to assess its effectiveness in managing the specific risks articulated in the financial institution’s Risk Assessment. Regular testing of the system should be supported by metrics, analysis, and reporting.