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Best Practices for Sanctions Screening and Watchlist Filtering

In 2019, a major bank was ordered to pay $1.1 billion for conspiring to violate the International Emergency Economic Powers Act (IEEPA) and other international money laundering controls. It included a criminal conspiracy involving some 9,500 transactions worth a quarter of a billion dollars to the benefit of sanctioned Iranian entities.

More than half of the transactions were the result of deficiencies in its compliance program, which allowed customers to request U.S. dollar transactions from within sanctioned countries.

This white paper looks at how regulated institutions should monitor and screen individuals, entities and transactions as well as best practices to optimize the results in order to avoid some of the penalties and fines associated with sanction violations.