RESOURCES EN PLAYBOOKS · GUIDEUPDATED 2026-03-04
Resources en Playbooks
Beleidssjabloon voor Sanctie-Herscreening
Een sjabloon voor het vastleggen van herscreeningsfrequentie, triggergebeurtenissen en escalatieregels voor klant- en leveranciersportefeuilles.
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.
§01What this workflow covers
SCOPE- 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.
§02Key statistics
DATA- Minimum policy dimensions
- 4 (frequency, triggers, ownership, escalation)
- ScreenVeritAI policy design template
- Control review cadence
- Monthly exception and completion review
- ScreenVeritAI compliance operations baseline
§03Compliance glossary
TERMS- 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.
§04Authoritative references
SOURCES- 01OFAC Sanctions Lists
U.S. Department of the Treasury
- 02EU Financial Sanctions Database
European Commission
- 03UN Security Council Consolidated List
United Nations Security Council
- 04FATF Guidance on Beneficial Ownership and Transparency
Financial Action Task Force
§05Expert perspective
NOTE“Risk controls perform best when sanctions checks and ownership context are reviewed together.”
§06Frequently asked questions
Q&A- 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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