Sanctions screening program

Description

Sanctions screening is the operational expression of a small set of overlapping prohibitions: don't transact with persons or entities on the OFAC Specially Designated Nationals list, the UK OFSI Consolidated List, the EU consolidated financial sanctions list, the UN Security Council list, and a growing inventory of country-specific and sectoral programs (the Russia sectoral lists, the Iran-related secondary-sanctions exposure, OFAC's 50% rule on majority-owned entities). Screening has to happen at three points: at onboarding (the customer or counterparty entering the platform), on transaction (each payment or trade against the relevant list), and on list updates (when a name is added, every existing customer is rescreened against the new entry). The operational pieces are the screening engine and its fuzzy-match scoring, the false-positive review queue that handles the inevitable common-name collisions, the escalation path for confirmed hits (typically blocking the transaction, freezing the account, and filing the relevant authority report), and the audit log that documents who reviewed what and when. Tuning is the recurring difficulty; too tight and the false-positive volume swamps the review team, too loose and a confirmed hit slips through.

Required by (5 regulations)

• US EAR

  15 CFR §744 + Part 744 Supp. — restricted-party screening as the parallel obligation alongside ECCN-based licensing.

  15 CFR §744 + Part 744 Supp.

• US OFAC

  31 CFR Part 501 + program-specific provisions; SDN List + 50% Rule + comprehensive country programs (Cuba, Iran, NK, Syria, Crimea/DNR/LNR); real-time screening at signup and transaction time.

  31 CFR Part 501 + program-specific provisions; SDN List + 50% Rule + comprehensi

• EU Dual-Use

  Regulation (EU) 2021/821, Article 12(4) + Commission Recommendation 2019/1318 — Internal Compliance Programme with restricted-party screening as the third of seven core elements.

  Regulation (EU) 2021/821, Article 12(4) + Commission Recommendation 2019/1318

• UK Export Control

  SAMLA 2018-based sanctions framework operates alongside the export-control regime; OFSI Consolidated List is the screening baseline.

  SAMLA 2018-based sanctions framework operates alongside the export-control regim

• Other Sanctions

  Consolidated multilateral screening (UN + AU DFAT + CA OSFI + JP METI/MOFA + SG MAS + CH SECO + others); commercial aggregators (Refinitiv, Dow Jones, LexisNexis, Sanctions.io) the operational baseline.

  Consolidated multilateral screening (UN + AU DFAT + CA OSFI + JP METI/MOFA + SG

Fulfilled by (4)

• comply-advantage · full · medium effort · $$
• refinitiv · full · high effort · $$$
• ofac-search · partial · low effort · $
• In-house build · high effort
  Maintaining list updates + fuzzy-match scoring is the part teams underestimate.

ClearLaunch does not accept payment from vendors. Methodology.

Evidence formats

• screening configuration
• hit / clear log
• list-update cadence
• risk-based exception policy