By Brian Monroe
September 22, 2016
As we have noted in recent round-ups, there has been a “perfect storm” of elements that have come together to bring scrutiny on financial crime programs to new heights, and sanctions compliance is no exception to that trend.
Along with multi-billion dollar penalties in recent years, companies have had to contend with major changes to key sanctions regimes related to Russia, the Ukraine, Iran and Cuba. Sanctions failings and the resulting enforcement actions have happened for a bevy of reasons, including lack of staff training, improperly tuned systems spitting out inaccurate results, or simply not enough staff to digest and follow up on alerts.
At the heart of the issue: keeping up with the entities that are added, or dropped, from sanctions programs can be a herculean challenge, and somehow uncovering related further ties to associated entities with secretive ownership controls can feel nearly impossible. The most extensive and rigorously-enforced sanctions programs are managed by the U.S. Treasury’s Office of Foreign Assets Control, or OFAC. Joining OFAC sanctions are those administered by the European Union, Canada, Japan, and many other nations, raising the level of compliance complexity.
While vendor options are plentiful in this space, ACFCS wanted to scour the web to find some free, open-source help when it comes to sanctions screening, either for tools themselves or a more readily readable summary of the actual programs in place.
Below are five open sources to support your forays into the complex and nebulous world of sanctions, hits, false positives and everything in between.
The ACFCS Resource Round-Up is a new feature from ACFCS highlighting open-source tools, databases, information sources and other resources that can be potentially useful for financial crime compliance, investigations and due diligence. As with all online open sources, these tools each have their own limitations, so users must always employ their own discretion in accessing these tools and validating and interpreting any results obtained.
OFAC Sanctions List Search
The official US site to search for specially-designated nationals (SDNs), which can encompass everything from potential ties to terrorists and arms traffickers to unsavory individuals trying to create nuclear weapons.
The site allows for searching individual names and companies, with a related to score to help gauge how close the match is to the actual blacklisted entity. It also allows for anyone to download consolidated SDN and non-SDN lists, allowing banks to weave the data into their own proprietary or vendor-driven systems.
Watchlist Resource Library
A library of watchlists and sanctions lists, maintained by the US and many other nations, curated by compliance professional Eric. A Sohn. While some of the links are not current, the library can still serve as a useful reference point for the sheer number and diversity of watchlists available internationally.
Zurich North America Sanctions Screener
This screening tool from the Swiss insurance giant allows both manual and bulk screening, offering an Excel template for bulk screenings, but with a maximum number of 7,500. It works with nearly every browser. The required information to use the tool is name, trade name or country.
Finra OFAC Search Tool
This is a tool provided by the chief self-regulatory body with dominion over the nation’s securities sector, the Financial Industry Regulatory Authority, or Finra. The regulator has been increasing its scrutiny of financial crime compliance programs at all manner of trading firms, both fining operations directly in the millions of dollars, but also sharing information with other federal bodies.
The tool allows users to check four separate sanctions boxes, including standard SDNs and even foreign sanctions evaders and has options to search for a word, partial or full phrase. The input is a simple box and names or companies must be separated, with a maximum of 500.
Now, we said we were going to stay away from paid, vendor-driven solutions. And, technically, we are. But this OFAC sanctions summary is a great, quick way to get a glimpse of what U.S. sanctions are in place for which countries and in what areas, be they trade, arms, terrorism, or other more obscure embargoes that still have to be on a compliance person’s radar screen.
Do you have any that we forgot? If so, email ACFCS at the address above.