Resources and Playbooks
How to Screen a New Customer for Sanctions
A step-by-step workflow to screen a new customer against sanctions, PEP and adverse media before activation — with an audit-ready evidence trail.
Updated
Start with a clear scope: who is being screened, which risk checks are required, and what evidence must be retained. Then run sanctions, ownership, and media checks in one repeatable process.
What this workflow covers
- Collect the customer legal name, aliases, and jurisdiction context.
- Run sanctions, ownership, and adverse media checks together.
- Document outcomes, rationale, and source links before approval.
- Set a re-screening cadence based on policy and risk tier.
Compliance glossary
- Sanctions screening
- A control process that checks a person or entity against sanctions and watchlist datasets.
- PEP
- Politically Exposed Person: an individual in a prominent public function requiring enhanced due diligence.
- UBO
- Ultimate Beneficial Owner: the natural person who ultimately owns or controls a legal entity.
Authoritative references
Expert perspective
“Risk controls perform best when sanctions checks and ownership context are reviewed together.”
Questions
Frequently asked questions
What information do we need before screening?
At minimum, legal name and identifying context such as country, registration data, or known aliases.
Which checks are usually required?
Sanctions, PEP exposure, adverse media, and ownership or control checks are common baseline controls.
How should we document decisions?
Store the screening result, source references, analyst rationale, and approval outcome.
When should customers be re-screened?
Re-screening should follow your risk-tier policy and trigger-based escalation rules.
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