AML programs
AML Sanctions Screening That Fits Your KYC Onboarding
AML sanctions screening is the part of an anti money laundering program that checks customers and counterparties against government sanctions lists. It runs during KYC onboarding and again over the life of the relationship. OfacScanner covers this sanctions control, while the rest of your AML program stays in your hands.
Onboarding check, new business customer
ReviewClose spelling to a listed alias
Customer country differs from the entry
Organization against organization
No shared registration number
Example scores for illustration. The reviewer decides.
What is AML sanctions screening
An anti money laundering program, or AML program, is the set of policies and controls a business uses to stop its services from being used for financial crime. In the United States the Bank Secrecy Act sets the base rules for banks, money services businesses and other covered firms. Around the world the Financial Action Task Force, known as FATF, publishes the standards that national AML laws follow.
Sanctions compliance sits next to AML and shares most of its data. Both start with knowing who the customer is. AML then looks at how money moves and whether activity is suspicious. Sanctions screening asks a narrower question with a hard legal answer. Is this person, company, vessel or wallet on a list that forbids doing business with it.
That is why most teams run sanctions screening inside their AML and KYC workflow, even though the legal basis is different. In the U.S. sanctions rules come from OFAC and apply to all U.S. persons, not only to firms covered by the Bank Secrecy Act. A clean AML review does not replace a sanctions check, and a sanctions check does not replace AML monitoring.
Where sanctions screening fits in an AML program
A typical AML program has several controls. This is what OfacScanner covers and what you run elsewhere.
| AML control | Purpose | Covered by OfacScanner |
|---|---|---|
| Customer identification and KYC | Collect and verify identity data | No, but screening uses that data |
| Sanctions screening | Check parties against official lists | Yes, OFAC and global lists |
| Ongoing sanctions monitoring | Re-screen customers after list changes | Yes, on Growth and higher |
| Payment screening | Check parties inside each transfer | Yes, on Scale and higher |
| PEP and adverse media checks | Find higher risk customers | No |
| Beneficial ownership | Identify who owns or controls an entity | No, you collect and review it |
| Transaction monitoring and SAR filing | Spot and report suspicious activity | No |
Being clear about scope helps your auditor see which control each tool supports.
How to add sanctions screening to KYC onboarding
Five steps that place the check where it does the most good.
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01
Collect the right fields
Ask for full legal name, date of birth for people, country, and registration or tax numbers for companies. These are the same fields KYC already needs.
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02
Screen before approval
Run the check after identity data is captured and before the account opens, in the app or through the sanctions screening API.
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03
Route possible matches
Clear results continue automatically. Review, Likely match and Exact match open a case for an analyst instead of blocking the whole queue.
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04
Decide and record the reason
The reviewer compares the details with the listed entry and closes the case with a written reason, saved with the score breakdown.
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05
Keep the customer under watch
Add approved customers to sanctions monitoring so later list changes are caught.
What an examiner usually asks to see
These points line up with the five parts of the OFAC Framework for Compliance Commitments from 2019. Management commitment, risk assessment, internal controls, testing and auditing, and training.
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A written risk assessment
Which customers, products and regions carry sanctions risk, and which lists apply to you.
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Documented screening rules
When you screen, which lists, which threshold, and why that threshold fits your risk.
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Evidence for each check
The list version, time, user and result for every screening, kept for the full retention period.
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Decisions with reasons
Why each possible match was cleared or escalated, and who decided.
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Proof of re-screening
That existing customers were checked again after list updates.
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Testing and training records
Periodic tests of the screening setup and training for the people who review matches.
Screening informs the decision and your team makes it
OfacScanner shows what the lists say, how close each name is and which list version was used. It does not decide whether to open an account, file a report or end a relationship. It also does not trace ownership, so entities owned 50 percent or more by blocked persons need your own ownership review. OFAC requires records of covered transactions to be kept for 10 years, so export your evidence if your plan retention is shorter. OfacScanner is not affiliated with OFAC or the U.S. Department of the Treasury.
AML sanctions screening questions
Another question? Write to [email protected].
Is sanctions screening part of AML?
Does OfacScanner replace my AML software?
When in onboarding should I screen?
Which lists should an AML program screen?
What threshold should we use?
Keep exploring
Screen your first name in seconds
Type a person or company name, see the risk rating and top candidates from the current OFAC list, and keep the evidence when you sign up.
Results support your compliance decisions, and the final decision stays with your team. OfacScanner is not affiliated with OFAC or the U.S. Department of the Treasury.