Sanctions Screening: Challenges and Control Considerations

Economic sanctions have evolved in complexity over time. Total embargoes were formerly common, and were enacted to completely block trade with disfavoured countries. List-based sanctions (also known as ‘smart’ sanctions) were later introduced, specifically targeting people and entities rather than entire countries.

Screening against targeted sanctions lists presents considerable challenges, given the complex corporate structures used to obscure underlying sanctioned parties, the inherent difficulties in name matching, and difficulties in screening for entities that are, directly or indirectly, 50 per cent or more owned by sanctioned parties, under OFAC’s 50 Percent Rule.

In the chapter, “Sanctions Screening: Challenges and Control Considerations” featured in GIR’s The Guide to Sanctions – Second Edition, Charlie Steele, Sarah Wrigley, Deborah Luskin and Jona Boscolo Cappon review current regulatory guidance for a successful sanctions screening programme, how screening relates to the core elements of the overall sanctions compliance programme, examples of enforcement actions focusing on screening failures, and screening in the context of a sanctions investigation.

Learn more in GIR’s The Guide to Sanctions – Second Edition.