Manually screening sanction lists is possible, but it is a time-consuming and potentially error-prone task. Sanction lists are regularly updated, and the multitude of names, organizations, and countries requires precise and careful verification.
Here are the basic steps you can follow if you want to screen sanction lists manually:
1. Obtain current sanction lists:
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- Download the current sanction lists from official sources, such as the United Nations, the European Union, the US Office of Foreign Assets Control (OFAC), and other relevant national authorities.
2. Compare names:
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- Compare the names of individuals, organizations, or countries in your business transactions with the entries on the sanction lists. Pay attention to possible matches.
3. Use different spellings:
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- Keep in mind that names may appear in different spellings or translations. Consider using synonyms, nicknames, or alternative spellings in your screening.
4. Consider alias names:
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- Individual entries in sanction lists may contain alias names or other identifiers. Make sure to check these as well.
5. Use automated tools:
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- If available, you can also use automated tools to support the screening process. There are software solutions and APIs (Application Programming Interfaces) specifically designed for screening against sanction lists.
6. Documentation and compliance records:
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- Maintain accurate documentation of your screening process. It is important to record the results in order to demonstrate, in the event of audits or reviews by regulatory authorities, that you have properly screened sanction lists.
However, it is important to note that manual verification has its limitations. In many business environments, especially when dealing with large volumes of data, the use of automated compliance tools based on machine learning or specialized algorithms is often more efficient and accurate. Such tools can search large databases in a short time while improving the accuracy of the verification.