Repeat checks when sanctions lists change
Sanctions lists change continually, so a single check at the start of a business relationship is not enough. Agree how often to check, how to review possible matches and where to keep the results.
When a name is added to a sanctions list
Covered by the regulation
A customer you checked earlier may later be added to a sanctions list. You need a way to check existing customers again when the lists change.
- The sanctions list changes
- A new or updated entry is found
- Customer and related-party names are checked
- A possible name match is found
- Someone reviews it and records their decision
If an entry is removed from a list, review what that means for your earlier decision before closing the case.
Illustrative example. Assess the documents and applicable rules in each case.
Article 26(4) requires regular checks. Credit and financial institutions must also check when a new person or company is listed. The regulation does not specify the technology to use or a fixed response time.
Read Article 26(4) in the regulationWhen details in a sanctions list change
Good screening practice
An existing record can gain another name, a different spelling or a date of birth. These details may reveal a connection that an earlier check missed.
For example, a customer’s name may match a newly added alternative name. Updated and removed records may also need review, even when the main name stays the same.