Sanctions compliance is broader than name screening. Institutions need to understand their products, payment corridors, counterparties, customer ownership and geographic touchpoints.
Control design should cover onboarding and ongoing screening, list updates, fuzzy matching, ownership and control analysis, payment screening, escalation and decision governance.
Effectiveness testing should assess whether meaningful alerts are detected and resolved well—not simply whether the system generates alerts.
Important: This FCT perspective is general information, not legal, regulatory or professional advice. Requirements and facts vary by institution and jurisdiction.
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