On 23rd July, Banking Technology published an article following recent cases where failures in sanctions screening has, at least, contributed to large fines and penalties paid by banks in the US – described as a clear wake-up call for anyone in the financial industry.  It refers to the Wolfsberg Group guidance on sanctions screening, and guidance issued by regulators.  Listing the “dos and don’ts” referred to in the title, it also cautions that screening goes well beyond a simple name matching process and requires examining data from widely disparate technologies and sanctions lists.  It also says that screening must cast a wide net, meaning a wide range of lists, companies and individuals must be included to reduce the risk for an institution to an acceptable level – listing some of them, and saying using the OFAC list alone is not enough.


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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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