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Sanctions Screening Guidance
Sanctions Screening in Real-Time vs. Periodic Screening
When it comes to sanctions screening, institutions must balance their obligations with regulatory requirements and risk profiles. For some institutions subject to local regulations, real-time screening of domestic payments may not be necessary. However, for those subject to multiple jurisdictions or mandates with varying risk profiles, periodic screening alone may not be sufficient.
- For institutions with low-risk profiles: Real-time screening of domestic payments may be unnecessary.
- For institutions with high-risk profiles: Periodic screening may not provide adequate protection against sanctions risks.
Data Elements within Transactions
Sanctions screening relies on the ability to identify and assess relevant data elements within transactions. The following data points are crucial for list-based and geographically based sanctions programs:
Relevant Data Elements
- Names of parties involved in transactions
- Addresses (for geographically based sanctions programs)
- Bank identification codes
- Free text fields (e.g., payment reference information or the stated purpose of a payment)
- International Securities Identification Numbers (ISINs) or other risk-relevant product identifiers
Limited Value Data Elements
Certain data elements, such as amounts, dates, and transaction reference numbers, offer little or no risk mitigation through screening.
Manner, Timing, and Frequency
Transaction screening should be performed at points in the lifecycle of a transaction where it can be stopped before a potential violation occurs. Institutions must pay particular attention to points within the transactional process where relevant information could be changed, modified, or removed to undermine screening controls.
- Screening should occur: At points in the transactional process where a potential violation can be prevented.
- Particular attention should be given: To points where information could be altered to circumvent screening controls.