Sanctions screening
Sanctions screening is the process of checking clients, their beneficial owners, and associated parties against official sanctions lists maintained by bodies such as the UK Office of Financial Sanctions Implementation (OFSI), the United Nations Security Council, the European Union, and the US Office of Foreign Assets Control (OFAC). Acting for a sanctioned individual or entity is a criminal offence.
sanctions screening should be run at onboarding and repeated at regular intervals or whenever circumstances change, since lists are updated regularly. A match must be escalated immediately.
How different roles use Sanctions screening
A good definition should change the next action for the person reading it.
Partner or director
Check whether this term affects acceptance risk, fee scope, supervision exposure, or sign-off responsibility.
ContinueMLRO or compliance lead
Map the term to evidence, escalation, monitoring, training, and inspection readiness.
ContinueClient-facing team member
Use the plain-English explanation to ask better client questions and write clearer file notes.
ContinueOther terms that go with Sanctions screening
A Politically Exposed Person is an individual who holds or has held a prominent public function — such as a head of state, senior government minister, senior civil servant, judge, military officer, or senior executive of a state-owned enterprise — and their close family members and known associates. PEPs carry elevated money laundering risk due to their access to public funds or political influence. Since the Financial Services and Markets Act 2023 (s.78) and the FCA's PS24/4 guidance, UK domestic PEPs are by default treated as lower risk than foreign PEPs unless other risk factors apply.
Ongoing monitoring is the continuous obligation to scrutinise transactions and client activity throughout a business relationship and to keep CDD records up to date. It requires watching for transactions or behaviour that is inconsistent with the stated purpose of the relationship or the expected risk profile.
A beneficial owner is the natural person who ultimately owns or controls a legal entity — such as a company or trust — or on whose behalf a transaction is being conducted. Identifying beneficial ownership is a core CDD obligation where clients are companies, partnerships, or trusts, since the legal owner and the true controlling person may be different.
Before you treat Sanctions screening as handled
- Confirm which regulation, policy, or internal procedure the term maps to.
- Document the decision or evidence trail in the client file, not only in email or chat.
- Escalate where the term indicates higher risk, sanctions exposure, PEP status, suspicion, or missing evidence.
- Keep the wording consistent across onboarding, review notes, training material, and inspection packs.
Put Sanctions screening into practice with Certivus
Knowing the term is the first step. Certivus gives you the workflows — client intake, CDD, EDD, PEP and sanctions screening, audit-ready records — to apply it across every client.
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