Sanctions Screening Guide for UK Accountants and Law Firms
In brief: Sanctions screening checks clients and relevant parties against sanctions data, then records whether possible matches were cleared, escalated, or treated as true matches.
Key points
- Screen at onboarding and when client or list risk changes.
- Review possible matches using identifiers, not name similarity alone.
- Keep an audit trail for searches, matches, decisions, and escalations.
How sanctions screening works
Sanctions screening starts with names and identifiers, but the real control is the review. A possible match needs to be checked against date of birth, address, nationality, company number, ownership, aliases, and source list details.
Who to screen
- Clients and applicants.
- Beneficial owners and PSCs.
- Directors, partners, trustees, and controllers.
- Third-party payers or funders where relevant.
- Existing clients on periodic review or trigger events.
When to screen
Screen before onboarding, before high-risk matters, when ownership changes, when a payment source changes, and when sanctions lists or risk alerts change.
What to keep
Keep search terms, date, source, result, possible-match review, outcome, reviewer, and next review trigger. If a match is escalated, keep the internal escalation trail.
Practical judgement
Not every possible match is a true match. Not every cleared match is low risk. A sanctions screening result should feed back into the client risk assessment.
This guide is general information for UK regulated firms. Sanctions change quickly, so always check the relevant official list or get specialist advice before making a client decision.