Sanctions Screening, Monitoring and Investigation
Screening
Screening compares parties, beneficial owners, directors, addresses, vessels and payment fields against sanctions lists. Design decisions that examiners probe: which lists, which fields, what fuzzy-matching logic and thresholds, how transliteration and name-order variation are handled, and whether screening runs at onboarding, on a periodic cycle, and on every list update. A match score is an indicator, not a determination - every potential match must go through a documented disposition workflow with maker-checker review.
Monitoring
Transaction monitoring should be risk-based and scenario-driven: high-risk geographies, dual-use or controlled goods, trade documents that disagree (invoice versus bill of lading versus manifest), third-party payments, structuring, sudden changes in business profile, opaque shipping patterns. Tuning is continuous: too many false positives causes alert fatigue and missed true hits; too few creates under-matching exposure.
Investigation and escalation
Preserve records, gather corroborating identifiers, determine whether a match is true, and decide: proceed, escalate, block, reject, exit, or seek a licence. Then document the rationale. Blocked property must be reported to OFAC within 10 business days of blocking, with annual reports thereafter; rejected transactions are also reported. Retain records for the required period.
Traps
- Clearing a hit on name similarity alone, without reviewing identifiers.
- Failing to screen beneficial owners and controllers.
- Not re-screening the existing book when a list is updated.
- Confusing PEP or adverse-media screening with sanctions screening.
- Undocumented dispositions - an unexplained cleared hit looks like no control at all.
Worked example
A 92 percent name match with a different date of birth and country is cleared with a written rationale. A 78 percent match with an identical address, date of birth and passport number is escalated and blocked. Score alone never decides.