Manually checking sanction lists is possible, but it’s a time-consuming and potentially error-prone task. Sanction lists are updated regularly, and the multitude of names, organizations, and countries requires accurate and careful verification.
Here are the basic steps you can follow if you want to manually check sanction lists:
1. Obtain current sanction lists:
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- Download the latest 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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- Consider that names may appear in different spellings or translations. You may want to use synonyms, nicknames, or alternative spellings when cross-referencing.
4. Consider aliases:
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- Individual entries in sanction lists can contain aliases or other identifiers. Make sure you check these as well.
5. Use automated tools:
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- If available, you can also use automated tools to assist with the reconciliation. There are software solutions and APIs (Application Programming Interfaces) specifically designed for sanction list screening.
6. Documentation and Compliance Records:
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- Maintain precise documentation of your screening process. It is important to record the results to demonstrate, in the event of audits or reviews by regulatory authorities, that you have properly checked sanction lists.
However, it’s important to note that manual checking has its limitations. In many business environments, especially when dealing with large volumes of data, using automated compliance tools based on machine learning or specialized algorithms is often more efficient and accurate. Such tools can scan large databases in a short time and thereby improve the accuracy of the check.
