What Should a Business Include in Sanctions Screening?

First announced: Governments and international bodies continue to update sanctions and financial-crime controls in response to changing risks.
Submitted by: NYBACS Compliance Desk

What changed

International transactions may require businesses to assess customers, owners, counterparties, intermediaries, goods, and destinations against the sanctions rules that apply to the transaction.

Who’s affected

Businesses involved in cross-border trade, payments, financial services, logistics, or supply chains that include international counterparties.

Immediate actions

  • Identify which sanctions regimes may apply to the business and its transactions.
  • Screen relevant parties at onboarding and at suitable points during a relationship.
  • Escalate potential matches for review before proceeding.
  • Keep records of screening results, review decisions, and updates to controls.

Practical note & timeline

Applicable restrictions depend on the jurisdictions and parties connected to a transaction. A possible screening match requires assessment against the relevant official lists and rules before deciding how to proceed.

Source: https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html

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