New Sanctions Designations: Effectively Managing Resources and Risk

Screening names and identifiers on the sanctions list alone is no longer sufficient to satisfy regulatory expectations. This paper highlights immediate actions for financial crime risk management in the wake of new sanctions designations, as relevant to the 50% rule and broader KYC, as well as other regulatory and reputational risk considerations. In this paper we bring into focus the importance of going beyond the sanctions list for screening and due diligence in order to identify exposure to customers that present material risk considerations for the control framework. In particular we address the following risk, data and relationship types that can be surfaced within the first few days following each new designation.