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Sanctions Screening Guidance for Financial Institutions

The Wolfsberg Group’s Sanctions Screening Guidance provides essential information for financial institutions (FIs) on assessing and implementing sanctions screening practices. Here are the key takeaways from this guidance.

Assessing Requirements

Understanding Regulatory Obligations

• FIs should assess their regulatory requirements and applicable sanctions programs.
• Domestic payments may not require real-time screening, but international transactions or those involving different jurisdictions may necessitate more stringent screening.

Data Elements within Transactions

Identifying Relevant Transaction Types

• FIs should identify relevant transaction types for sanctions screening (e.g., names of parties involved, addresses, bank identification codes).
• Some data elements are more relevant when combined with other attributes or references (e.g., sectoral sanctions risk requires detection of multiple factors).

Manner, Timing, and Frequency

Transaction Screening Best Practices

• Transaction screening should occur before a potential violation occurs.
• Screening should take place at points in the transaction lifecycle where relevant information can be changed, modified, or removed.
• Particular attention should be directed to points where screening controls could be undermined.

Key Takeaways

• FIs must assess their regulatory requirements and applicable sanctions programs.
• Transactional records should be screened at a point in time before a potential violation occurs.
• Relevant data elements for sanctions screening may vary depending on the transaction type and jurisdiction involved.
• Screening controls should be implemented at points where relevant information can be changed or removed to prevent undermining of screening.