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Wolfsberg Sanctions Screening Guidance

Introduction

The Wolfsberg Sanctions Screening Guidance provides financial institutions (FIs) with an overview of sanctions screening best practices. This guidance emphasizes the importance of understanding the risk landscape and implementing effective screening processes to prevent potential violations.

Contextualizing Sanctions Screening

Sanctions screening should be contextualized within a FI’s local regulatory requirements, including jurisdictions’ local sanctions and Know Your Customer (KYC) requirements when on-boarding clients. Here are some key considerations:

• Local Regulatory Requirements: FIs must comply with local laws and regulations, including those related to sanctions and KYC.
• Jurisdictional Differences: Sanctions programs vary across jurisdictions, requiring FIs to tailor their screening processes accordingly.

Data Elements within Transactions

When conducting sanctions screening, FIs should assess which transaction types are relevant for screening. Here are some key data elements to consider:

• Names of Parties Involved: Names of parties involved in the transaction are relevant for list-based sanctions programs.
• Addresses: Addresses are more relevant to screening against geographical sanctions programs.

Manner, Timing and Frequency

Transaction screening should be performed at a point in time where a transaction can be stopped before a potential violation occurs. This typically occurs at several points in the lifecycle of a transaction:

• Initial On-boarding: Screening should be performed during the initial on-boarding process to ensure compliance with local regulations.
• Ongoing Monitoring: Ongoing monitoring is necessary to detect and prevent potential violations.
• Transaction Lifecycle: Screening should occur throughout the transaction lifecycle, including at settlement and payment.