Publication of Guidance on Sanctions Screening

The Wolfsberg Group is pleased to publish new guidance on how Financial Institutions (FIs) should carry out sanctions screening.

Sanctions screening is a control employed within FIs to detect, prevent and manage sanctions risk and should be undertaken as part of an effective Financial Crime Compliance (FCC) programme, to assist with the identification of sanctioned individuals and organisations, as well as the illegal activity to which FIs may be exposed. In light of the continuous expansion and growing complexity of international sanctions regulations, the objective of this publication is for the Wolfsberg Group to provide guidance to FIs as they assess the effectiveness of their sanctions screening controls.

The fundamentals of the guidance are derived from legal/regulatory requirements, as well as expectations and global industry best practice. It is not intended to suggest all FIs should apply all elements in this guidance to the same level; rather, it attempts to demonstrate where sanctions screening can be an effective part of a wider sanctions compliance programme, where it has limitations as a control and where a risk based approach is appropriate. The guidance includes sections on the definition of sanctions screening, the fundamental elements of a sanctions screening programme, consideration of a risk based approach, technology, alert generation and handling, reference data, transaction screening, list management and lookbacks.

As with all materials published by the Wolfsberg Group, these are designed to provide FIs with an industry perspective on effective financial crime risk management.

There are a number of ways FIs can seek to adhere to the various documents published by the Wolfsberg Group. However, the means by which each FI choses to adopt these documents must make sense for each individual firm, recognising that one size doesn't fit all and that each FI's risk mitigation strategy must be tailored to meet its risk appetite.

We hope that you find this new Guidance of interest and the undersigned, as well as the Wolfsberg Group Secretariat, remain at your disposal for further information or questions.

John Cusack, Co-Chair, The Wolfsberg Group William Fox, Co-Chair, The Wolfsberg Group Tracy Paradise, Executive Secretary, The Wolfsberg Group