Sanction Screening

What is Sanction Screening?

Sanction Screening is a compliance requirement for institutions that compare clients' data against a list of people, countries, and business entities that are provided by both domestic and international regulatory bodies, to:

1. Assess whether they are forbidden from working with potential clients and partners (e.g. Office Foreign Asset Control – OFAC – in the U.S.), and
2. Assess higher risk clients that require enhanced due diligence and reporting (e.g. Politically Exposed Persons - PEP - Internationally or Domestically).

The eDNA™ Database

Accuant also has an eDNA™ database that was built from digital transactions across the financial ecoystem includes user descriptions, businesses, and relationships to other users and businesses

Users and businesses within the eDNA™ database are described based on a set of attributes, which is used to extend sacntion matching against other recorded profiles:

• Physical addresses,\

• E-mails,\

• Phone numbers,\

• Payment instruments,\

• Date of births,\

• Devices,\

• Articles of incorporation address,\

• Principals,\

• Ultimate beneficiaries, etc.\

e.g. Accuant eDNA™ example:

For example, if User X is transferring money to User Y, a normal sanctions screening procedure would check User X and User Y. With eDNA™ if User Y’s address is associated with User Z, who is a principal of a company on the OFAC list, eDNA™ will alert you to the match within our network of connections.

- U.S. Drug Enforcement Administration — Major International Fugitives

- U.S. Marshals Service — Major Fugitives Cases — Top 15 Most Wanted — Most Wanted

- U.S. Secret Service — Most Wanted

- US Department of State Diplomatic List

- Our own Political Exposed Persons (PEP) list.

Screening Lists

Accuant screens users against the following public data sources:

• Arms Export Control Act (AECA) Debarred List\

• Bureau of Industry and Security — Denied Persons List — Entity List — Unverified List\

• Chiefs of State and Cabinet Members of Foreign Governments\

• Consolidated List of Persons, Groups, and Entities Subject to E.U. Financial Sanctions (EU Freeze List)\

• Consolidated UNSC Sanctions Lists\

• Department of State Designated Terrorist Organizations\

• Department of State Terrorist Exclusion List (TEL)\

• FBI Most Wanted Terrorists\

• Foreign Consular Offices in the US\

• Immigration and Customs Enforcement Most Wanted Fugitives\

• Interpol Recently Wanted\

• Japan Foreign End Users of Concern\

• Naval Criminal Investigative Service — Wanted Fugitives\

• Nonproliferation Sanctions\

• Non-SDN Iranian Sanctions Act List (NS-ISA)\

• Office of the Superintendent of Financial Institutions’ Anti Terrorism Financing List\

• Office of Foreign Assets Control — Foreign Sanctions Evaders List\

• (OFAC FSE) — Specially Designated Nationals List\

• (OFAC SDN)\

• Palestinian Legislative Council (PLC) List\

• Royal Canadian Mounted Police — Wanted\

• Sectoral Sanctions Identifications (SSI) List\

• The List of Foreign Financial Institutions Subject to Part 561 (the Part 561 List)\

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Resources:

Accuant Sanction Screening Overview
Consumer API Sanction Screening
Merchant API Sanction Screening
Periodic Testing for Sanctions