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Sanctions Screening Guidance

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The Wolfsberg Group’s Sanctions Screening Guidance emphasizes the importance of real-time sanctions screening, particularly for international transactions. However, it acknowledges that domestic payments may not require real-time screening if the Financial Institution (FI) is subject to the same local regulatory requirements as the jurisdictions involved.

Real-Time vs. Scheduled Transactions

Why Real-Time Screening Matters

Real-time sanctions screening is crucial for international transactions to prevent potential violations from occurring. However, domestic payments may not require real-time screening if the FI is subject to the same local regulatory requirements as the jurisdictions involved.

Data Elements within Transactions

When assessing which transaction types are relevant for sanctions screening, FIs should identify the attributes within those records that are relevant for sanctions screening. The following data elements offer varying levels of risk mitigation through screening:

• Names of parties involved in the transaction (relevant for list-based sanctions programs)
• Addresses (more relevant to geographic sanctions programs)
• Amounts, dates, and transaction reference numbers (little or no risk mitigation)

Common Transactional Attributes Screened

The following attributes are typically screened as part of a sanctions screening process:

• Parties involved in a transaction (remitters and beneficiaries)
• Agents, intermediaries, and FIs
• Vessels (with International Maritime Organization (IMO) numbers)
• Bank names, Bank Identifier Codes (BIC), and other routing codes
• Free text fields (e.g., payment reference information or stated purpose of the payment)
• International Securities Identification Numbers (ISINs) or other risk-relevant product identifiers
• Trade finance documentation (including importer/exporter, manufacturer, drawee, drawer, notify party, signatories)

Manner, Timing, and Frequency of Screening

Transaction screening should occur at a point in time where a transaction can be stopped before a potential violation occurs. This typically happens at various points in the transaction lifecycle, but certainly prior to executing any commitment to move funds.

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