Resources and Playbooks
Sanctions Re-Screening Policy Template
A template for setting re-screening frequency, trigger events, and escalation rules across customer and vendor portfolios.
Updated
One-time checks are not enough for sustained compliance. This policy template helps define recurring re-screening schedules and event-driven triggers based on risk tier, jurisdiction exposure, and business criticality.
What this workflow covers
- Set baseline frequencies by risk tier: low, medium, and high risk.
- Define trigger events such as ownership changes, jurisdiction changes, or adverse media hits.
- Assign ownership across first-line operations and second-line compliance teams.
- Measure policy adherence with monthly control metrics and exception logs.
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
How often should sanctions re-screening run?
Sanctions re-screening frequency should be risk-based: high-risk and PEP-adjacent counterparties are re-screened more often than low-risk ones, and any sanctions-list update or trigger event prompts an immediate check.
Which trigger events should force immediate re-screening?
Ownership changes, major adverse media events, and material jurisdiction changes should trigger immediate checks.
Who should own the re-screening policy?
Compliance should own policy design, while operations execute recurring checks and escalation workflows.
How can we prove the policy is working?
Track completion rates, time-to-review, false-positive rates, and unresolved escalations by risk tier.
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