How to retain and repeat sanctions screening

What the record should explain

Save persons and roles, name variants, timing and each source’s outcome. Distinguish publication, retrieval and screening times. Attach original identifiers and confirmation/exclusion reasons for alerts. Mark missing sources and alternative procedures. A PDF cover or similarity score alone does not adequately explain what was done.

Documentation forming part of AML identification or due diligence is governed by Section 16. Ordinary businesses do not automatically adopt AML retention because they use the same software. Set purpose, legal basis, duration and access according to status. Public source data differs from individual client files; sensitive notes must not enter public snapshots.

Triggers for fresh screening

Define events: new entries, changed owners, representatives, counterparties, banks, services or destinations and significant transactions. Add periodic frequency based on risk and sector rules. A universal interval does not explain proportionality. Refresh long-inactive relationships before new performance rather than relying only on the original contract date.

A list-update notification does not rescreen clients unless monitoring is actually configured. Assign responsibility for processing updates, finding affected files and documenting resolution. Record coverage gaps and catch-up. Test responses to aliases, delistings and ownership changes as well as new rows.

Preserve history and accountability

Attach new conclusions with dates and change reasons. Confirmed relevant alerts require current action; old negative reports do not authorise continuation. Export evidence, reasons and source status. Assign cover for staff absence and verify that records remain retrievable after software-provider termination.

A repeated check must be a new action

For repeated screening, save a new time, actual source versions, current inputs and result. Keep the link to the previous record so changes remain visible. Record technical failure as a failed attempt without changing the last successful check date. A newly generated export from old data differs from a fresh check against current distributions.

Ownership changes may also alter the screened-person list. Do not compare only match counts. Document added persons, ended links and why coverage is sufficient for the decision. For an office provider, a change of representative or unusual redirection of the service may trigger review. Use calendar intervals alongside these triggers; they alone do not ensure a response to material changes during a relationship.