24 Jan 2019
A group comprising the world’s top banks has published guidance on how financial institutions should carry out sanctions screening.
The notes are derived from regulatory requirements and global industry best practice, it said.
“[The guidance] 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 Wolfsberg Group said.
The guidance includes the fundamental elements of a sanctions screening programme, consideration of a risk based approach, technology, alert generation as well as reference data.
It touches on a variety of topics, including risk assessments, and recommends that the decision making and governance structure be documented and supported by analysis and testing.
Regarding screening technology and generating productive alerts, it says a robust model jointly uses expertise from IT, Operations and financial crime compliance to ensure appropriate alert generation.
Link to the new guidance here
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