Checked once, then never again
When a client first instructs the firm, their name is run through a sanctions check as part of onboarding. The result is saved. Then the matter runs for eighteen months, the client instructs on two more matters, and nobody checks again. Meanwhile sanctions lists are updated regularly, sometimes several times a week when events move quickly.
Your compliance lead knows this is a gap. The only way to close it by hand is to rerun every active client and related party one by one, which never gets done.
Why rescreening falls through
Onboarding checks are tied to an event: a new client or a new matter. Rescreening has no event to trigger it, so it depends on someone deciding to do it. Even when your verification provider offers ongoing monitoring, it may cover only individuals checked through it, not company clients, their owners, or parties added to matters later.
The lists themselves are messy to compare against: names transliterated from other alphabets, aliases, companies with several names. A simple exact-match search misses a lot and a loose one floods the reviewer with false alarms.
| Who needs rescreening | Why they are often missed |
|---|---|
| Active individual clients | Checked only at onboarding |
| Company clients | Not covered by individual monitoring |
| Beneficial owners and directors | Recorded in notes, not as screenable parties |
| Parties added to matters later | Not part of the original check |
What the gap costs
Acting for a sanctioned person without knowing it is a serious matter for any firm. Even if it never happens, not being able to show how the firm keeps its screening current is a weakness in any review of its anti-money laundering controls. And a one-off manual rescreen, when it is finally done, takes your compliance lead away from everything else for days.
False alarms have a cost too. A screening tool that produces hundreds of weak matches teaches people to click through them.
How we build scheduled rescreening
- Screening list: we compile active clients, company clients, recorded beneficial owners and directors, and key parties from your practice management system into one list, refreshed daily.
- Official lists: the tool downloads the sanctions lists your firm uses, such as the UK consolidated list published by the government, whenever they update.
- Matching: names are compared with fuzzy and phonetic matching, handling aliases, transliteration and company suffixes, and weighted by other details you hold such as date of birth or nationality.
- Review queue: possible matches go to your compliance lead with both records side by side and the reason for the match. Nothing is decided automatically.
- Decision record: each match is marked as a false positive, a true match or needing escalation, with a note, and the record is kept.
- Evidence of screening: a report shows when each client was last screened and against which list version.
What a genuine match means, and what the firm does next, is for your MLRO and compliance lead under your policies. The tool keeps the screening current and the record complete.
What compliance gets from it
Every active client and relevant party is rescreened whenever the lists change, without anyone running searches by hand. The compliance lead reviews a short queue of real candidates with the evidence shown. The firm can show when each client was last screened and how every match was resolved.
The one-off rescreening project that never quite happens stops being needed.
Do these apply to you?
- Clients are screened at onboarding and not again.
- Company clients' owners and directors are not screened routinely.
- Rescreening would mean running names through a website one at a time.
- Your screening tool produces so many weak matches that people skim them.
- You could not easily show when a client was last screened.