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ARTICLE · 01 NOVEMBER 2021

Best Practices In Internal Lists Maintenance For Financial Crimes Compliance

Financial institutions employ screening—using lists of names, entities, persons, or countries derived from various sanctions or prohibited persons lists to identify possible legal restrictions (e.g., sanctions)...

United StatesCompliance

Financial institutions employ screening-using lists of names, entities, persons, or countries derived from various sanctions or prohibited persons lists to identify possible legal restrictions (e.g., sanctions), fraud, or other concerns with respect to a relationship or transaction-as an essential part of an effective financial crimes compliance (FCC) program.

Screening is dependent on data sets and lists of sanctions indicators. These lists, which incorporate records generated by governmental agencies as well as internal lists that reflect the financial institution's knowledge about its own exposure to sanctions risks, must be accurate, reliable, up to date, refreshed frequently, and relevant to the institution's unique risks. Rigorous management of these lists promotes screening consistent with the institution's risk appetite, including the identification of potential prohibited targets.

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