Sanctions Screening Advisory

Set clear ownership and coverage

The starting point is the firm's sanctions exposure: customer and counterparty relationships, payments or other transactions, products, channels, relevant jurisdictions and any trade-related activity in scope. A discussion can consider who owns policy, list maintenance, screening configuration, alert decisions and escalation; how group or third-party arrangements are overseen; and how senior management receives useful information about exposure, exceptions and control changes.

Coverage questions include which customers, related parties, counterparties, payments or other records are screened, when checks occur, how repeat checks respond to new designations, and what happens when systems or data feeds are unavailable. For UK financial sanctions, OFSI guidance points users to the UK Sanctions List and makes clear that the specific legislation and facts govern the restrictions. Other lists or controls may be relevant depending on the organisation's activities, contracts and jurisdictions.

Examine list data and human triage

A review conversation can examine how list sources and updates are selected, checked and applied; whether screening data contains enough identifying information; and how the firm documents configuration changes and testing. Human triage procedures can be considered for information requests, comparison of identifiers, decision rationale, escalation, timely holds where appropriate, record keeping and review of unresolved alerts. Procedures should help staff recognise that a name match is a signal to assess, not by itself a conclusion that a person is designated.

The FCA's May 2026 review highlighted governance, list management, data feeds, screening coverage, configuration and alert handling as areas where controls can fail. A conversation can use that guidance to frame questions about the organisation's arrangements without claiming to deliver a formal legal assessment, audit or guaranteed detection outcome.

• Named control owners, escalation paths and senior oversight
• Applicable UK Sanctions List and other relevant list sources, with update controls
• Coverage across customer, counterparty, ownership and transaction data in scope
• Documented human review, decision rationale, escalation and continuity arrangements

Keep advisory boundaries clear

An advisory review can examine the organisation, its activities and jurisdictions, screening process and relevant records. Findings inform questions for the firm's decision-makers. Determining legal status, granting clearance and interpreting sanctions legislation remain separate responsibilities; potential matches and ownership questions must be handled under applicable rules, with legal advice where needed.

Sanctions advisory focuses on control design and governance from screening to human decision. Testing match rates, false positives, thresholds and alert effectiveness examines screening performance. Tools and lists support a control framework, while the firm retains responsibility for its decisions and obligations.