Sanctions screening
Sanctions screening in financial and capital markets is under concurrent pressure from the U.S. Department of the Treasury's Office of Foreign Assets Control, the Financial Crimes Enforcement Network, and the European Banking Authority, each of which has issued updated expectations on automated screening system adequacy and false-positive remediation workflows in the past two years. OFAC's 2021 Sanctions Compliance Guidance for the Financial Sector remains the operative framework for U.S. broker-dealers and asset managers, but EBA's revised AML/CFT guidelines have since pushed EU-licensed institutions toward stricter real-time screening cadences for correspondent banking relationships. Compliance teams are now reconciling those two regimes where cross-border transaction flows touch both jurisdictions.
Watch
- OFAC 50 Percent Rule interpretations affecting indirect ownership in fund structures
- EBA travel rule technical standards: implementation deadlines for crypto-asset service providers
- FinCEN beneficial ownership registry: screening obligations against the new database go live
- Delistings and SDN list updates that require retroactive position review within 10 business days
- UK OFSI enforcement trend: fines issued for delayed self-disclosure of screening hits
Recent material activity in Financial & Capital Markets
Active monitoring in place across Financial & Capital Markets. Material developments related to sanctions screening will appear here as they are published.