Lesson 3 · Practitioner · Both · 20 min
Sanctions, PEP & Screening Operations
How list-based screening, PEPs, and adverse media fit into onboarding and continuous monitoring—and how PMs reduce false positives without weakening controls.
Objectives
- ▸Define sanctions vs PEP obligations in product language
- ▸Design screening touchpoints (onboarding, periodic, event-driven)
- ▸Specify match disposition workflows and auditability
- ▸Balance name-matching sensitivity with ops load
Sanctions lists (UN, OFAC, EU, UK HMT, and domestic lists) prohibit dealing with designated persons, entities, vessels, and sometimes sectors/jurisdictions. Screening must cover customers, UBOs, and often payees / counterparties depending on product.
- Exact vs fuzzy matching: too strict misses aliases; too loose floods ops.
- Secondary sanctions and sectoral sanctions complicate cross-border products.
- True matches require freeze / reject / escalate per policy—not silent passes.
Partner bank reality
Correspondent banks and sponsors will diligence your screening vendor, lists coverage, and alert aging. Product SLAs for case closure are commercial requirements.
Key terms
SanctionsOFACPEPAdverse mediaFuzzy matchingTrue match