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Best Practices for Sanctions Screening and Watchlist Filtering

In 2019, a major bank was ordered to pay more than $1 billion for conducting illegal financial transactions that violated sanctions against Iran and other countries.

This criminal conspiracy resulted in the bank processing approximately 9,500 transactions worth approximately $240 million through U.S. financial institutions for the benefit of Iranian entities. More than half of the transactions were the result of deficiencies in the bank’s compliance program.

This bank is not alone. According to the Manhattan District Attorney’s office, since 2009, eleven banks have forfeited more than $14 billion in settlements for U.S. sanctions violations and violations of New York State law.

This comprehensive reference document looks at:

  • How to take a risk-based approach to screening individuals and entities
  • How to use sanctions and watch lists
  • Best practices when using sanctions lists
  • What should be included in an OFAC compliance program
  • Dos and don’ts to avoid OFAC sanction violations
  • How to monitor high-risk and other controlled jurisdictions
  • What to look for screening high-risk professions and businesses

“When a global bank processes transactions through the U.S. financial system, its compliance program must be up to the task of detecting and preventing sanctions violations—and when it is not, banks have an obligation to identify, report, and remediate any shortcomings.”