Compliance playbook
Sanctions screening best practices
The practical parts that reduce false positives and help you pass audits: matching logic, tuning, evidence, and re-screening strategy.
1) Match on more than just names
Names are noisy. Use identifiers whenever you can: country, date of birth (individuals), registration numbers (entities), addresses, and document IDs.
2) Tune thresholds and review workflows
Two teams can screen against the same lists and get radically different false-positive rates. The difference is tuning and consistent review steps. Define:
- Matching thresholds per entity type and geography
- When to escalate to compliance leadership
- Disposition reasons (clear, true match, needs more info)
- Evidence requirements (what must be recorded)
3) Define re-screening policy (and prove it)
A common audit question is not just “do you screen,” but “when did you screen?” Choose a policy (on list updates, scheduled, or both) and keep timestamps for each screening event.
4) Build an audit trail by default
Save enough data so a third party can reconstruct the decision: inputs, match candidates, identifiers considered, reviewer notes, approvals, and timestamps. This is especially important for borderline cases.
5) Connect screening to monitoring
Screening is a point-in-time check. Monitoring catches behavior. If you have transactions, plan for transaction monitoring and re-screening at an appropriate cadence.