Performing Sanctions Checks: A Comprehensive Guide

Performing a sanctions check is a crucial step for businesses and financial institutions to ensure compliance with global regulations and avoid engaging with sanctioned individuals or entities.

This comprehensive guide outlines the process and best practices for conducting effective sanctions screening.

What Are Sanctions?

Sanctions are a form of punitive measure that are typically imposed by governments or international organizations on countries, entities, or individuals that have violated certain laws or regulations.

The nature of sanctions can range from financial restrictions, such as freezing assets or limiting access to financial markets, to trade bans that prohibit the import or export of certain goods. In more severe cases, sanctions can even include military action.

Regardless of their form, sanctions are a powerful tool used by nations and international bodies to maintain order and stability in the global arena.

Why Are Sanctions Implemented?

Sanctions are implemented as a strategic tool by governments and international organizations to exert pressure on entities that violate international laws or regulations. The primary objective of these sanctions is to exert pressure on the offending party, compelling them to comply with the established norms and regulations.

The imposition of sanctions is often driven by political and economic conflicts between nations. For instance, a country may impose sanctions on another to express disapproval over political differences and exert diplomatic pressure.

Sanctions can also be used as a response to trade disputes or to prevent the flow of financial resources to entities deemed a threat to international security or stability.

Types of Sanctions

Economic Sanctions

• Trade Embargoes: Restrict or prohibit trade with a specific country or region. This can include limitations on imports, exports, and financial transactions.
• Asset Freezes: Freeze the assets or financial resources of targeted individuals, entities, or governments, preventing them from accessing funds held in banks or other financial institutions.
• Financial Sanctions: Restrict access to international financial markets, such as prohibiting transactions involving specific currencies, financial instruments, or banking services.

Military Sanctions

• Arms Embargoes: Prohibit the sale, transfer, or export of military equipment, weapons, or technology to a specific country or entity.
• Military Intervention: Use military force or threats of military action to enforce compliance with sanctions or address security threats posed by the targeted party.

Targeted Sanctions

• Individual Sanctions: Impose travel bans, asset freezes, or other restrictions on specific individuals or entities deemed responsible for human rights abuses, corruption, or other illicit activities.
• Sectoral Sanctions: Target specific sectors of the economy, such as energy, finance, or technology, with restrictions on trade, investment, or technology transfer.

Diplomatic Sanctions

• Diplomatic Isolation: Reduce or sever diplomatic relations with a targeted country, including recalling ambassadors, closing embassies, or imposing travel restrictions on diplomats.
• Expulsion of Diplomats: Expel diplomats or officials from the targeted country's embassy or consulate in response to perceived violations of international norms or agreements.

What Is a Sanctions List?

Sanctions lists are official compilations of individuals, entities, organizations, and countries identified by governments or international bodies as subject to various sanctions. These lists are part of regulatory efforts to control the behavior of the listed parties due to their involvement in activities deemed unacceptable, such as terrorism, narcotics trafficking, arms proliferation, human rights abuses, and other threats to international peace and security.

Why Do Companies Need to Screen for Sanctions and Politically Exposed Persons (PEPs)?

Compliance with Regulations

Many countries have strict regulations in place to prevent money laundering, terrorist financing, and corruption. Screening for sanctions and PEPs helps companies comply with Anti-Money Laundering (AML) regulations. Non-compliance can result in severe penalties, including hefty fines and legal repercussions.

For instance, the Financial Action Task Force (FATF) provides recommendations to combat money laundering and terrorist financing, and screening for PEPs is one of the measures recommended.

Risk Management

Dealing with sanctioned individuals or entities can expose a company to significant legal, financial, and reputational risks. Similarly, engaging with politically exposed persons, who may have access to public funds or hold influential positions, can pose risks related to corruption and bribery.

Sanction and PEP screening help mitigate these risks by identifying such individuals before entering into business relationships or transactions with them.

Reputation Protection

A single association with an individual or entity involved in illicit activities can tarnish a company's reputation, leading to a loss of customer trust and potentially devastating financial consequences. Any negative publicity resulting from non-compliance with regulations or involvement with dubious entities can harm a company's brand image.

By conducting thorough sanction and PEP checks, companies can proactively safeguard their reputation.

When Should Companies Conduct Sanctions Screening?

• Customer Onboarding
• Transaction Screening
• Supplier and Vendor Due Diligence
• Employee Background Checks
• Mergers and Acquisitions (M&A)
• Periodic Reviews and Audits
• Ad Hoc Screening

How To Perform a Sanctions Check

Here's a step-by-step guide on how to perform a sanctions check:

1. Gather relevant information about the individuals, entities, vessels, or countries involved in the transaction or business relationship.
2. Obtain access to relevant sanctions lists from government agencies, international organizations, and regulatory authorities.
3. Integrate sanctions screening into the company's operational systems, such as customer onboarding processes, transaction monitoring systems, and payment processing platforms.
4. Use name-matching algorithms to compare the names of individuals, entities, vessels, and countries against the sanctions lists.
5. If a potential match is identified during the screening process, the system generates an alert to notify compliance personnel.
6. Compliance personnel review the alerts generated by the screening system to determine whether a true match exists. If a true match is confirmed, take appropriate action in accordance with internal policies and regulatory requirements.
7. Maintain detailed records of the screening activities, including the results of screenings, any alerts generated, and the actions taken to address potential matches.
8. Generate reports summarizing the screening activities for internal use and to demonstrate compliance with regulations to external stakeholders, such as regulators and auditors.
9. Continuously monitor sanctions lists for updates, including new sanctions, modifications to existing sanctions, and delistings.

Challenges in Sanction Checking

• Complexity of Sanctions Lists: Sanctions lists can be extensive and complex, with multiple jurisdictions imposing sanctions for different reasons. Keeping track of these lists and ensuring they are up-to-date can be challenging, especially for multinational companies operating in multiple jurisdictions.
• Variability in Data Quality: The quality of data available for screening can vary significantly. Names may be misspelled, aliases may be used, and identifying information may be incomplete or inaccurate. This variability can lead to false positives or false negatives during the screening process.
  Recommended reading: How to Reduce False Positives in AML Systems
• Volume of Transactions: Companies with high transaction volumes may face challenges in processing sanctions checks efficiently and in a timely manner. Screening every transaction in real time can strain resources and potentially impact operational efficiency.
• Resource Constraints: Companies may lack the necessary resources, including skilled personnel and advanced technology, to effectively perform sanctions checks. Limited budgets, competing priorities, and resource constraints can hinder the implementation of robust sanctions screening processes.
• Timeliness of Updates: Sanctions lists are frequently updated to reflect new sanctions, modifications to existing sanctions, and delistings. Ensuring that screening systems are updated promptly to reflect these changes and that screening processes are conducted in real-time can be challenging.

Sanctions Screening Solutions

Several sanctions screening solutions are available to help companies efficiently and effectively comply with sanctions regulations and mitigate risks associated with engaging with sanctioned individuals, entities, vessels, or countries.

Sanctions Screening Software

Dedicated sanctions screening software solutions are designed to automate the screening process and efficiently identify potential matches against sanctions lists. These solutions often utilize advanced name-matching algorithms, real-time screening capabilities, and customizable risk scoring to enhance accuracy and reduce false positives.

Compliance Platforms

Comprehensive compliance platforms offer integrated solutions for sanctions screening, anti-money laundering (AML) compliance, know your customer (KYC) processes, and other regulatory requirements. These platforms typically provide centralized data management, configurable workflows, and reporting capabilities to streamline compliance operations.

Risk-Based Approach

A risk-based approach to sanction checking involves prioritizing high-risk transactions, customers, and geographic regions. By allocating resources and applying enhanced due diligence measures where the risk of sanctions violations is highest, companies can safeguard their operations against potential sanctions-related consequences.

How sanctions.io Can Help

The service offered by sanctions.io allows clients to access our sanctions database, which pools global sanctions lists together into one digital asset. For example, sanctions.io's developer-friendly database contains all the significant international sanctions lists from countries such as Australia, Canada, Switzerland, France, the UAE, and many more. Additional lists are always available on demand. 

sanctions.io is a highly reliable and cost-effective solution for sanction checking. AI-powered and with an enterprise-grade API with 99.99% uptime are reasons why customers globally trust us with their sanctions screening needs. 

To learn more about how our sanctions, PEP, and criminal watchlist screening service can support your organization: Book a free Discovery Call.

We also encourage you to take advantage of our free 7-day trial (no credit card is required).

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