Sanctions Screening: When,
How, and What to Screen
To reveal potential sanctions exposure in your bank’s trade finance operations, you should
have a trade finance-specific sanctions screening policy and procedures. These should
cover when to conduct screenings, how to screen, and what data to screen.
Question Guidance
Banks should screen data at multiple points during the life cycle of the
When to screen
trade transactions as new or additional information becomes available.
The points at which data should be screened may vary based on the
product or service involved.
Potential triggers for screening include: the start of the transaction
(e.g., at issuance or advisement), upon payment, upon settlement,
when documents are received, and when an amendment is requested.
How to screen Banks should determine the appropriate method for screening (e.g.,
relevant sanctions lists, manual vs. automatic, screening technology,
scheduled vs. ad hoc screening), as well as how staff should assess
potential matches to determine whether the transactions involve
true sanctioned parties or are false positives.
Banks should develop a standardized list of critical transaction
What to screen
data elements to screen from payment messages (e.g., SWIFT
messages), as well as data from trade transaction documentation to
collect and screen.
While critical data fields will vary based on the product or
service, your bank should consider screening these fields:
• Jurisdictions: Counterparty location, counterparty bank’s
location, country of origin and designation, shipping route
(including ports of loading, transshipment and discharge), vessel
registration
• Participating banks
• Vessels: Name(s) (including prior names), owner(s), International
Maritime Organization (IMO) number
• Goods/commodities: For dual-use items and other high-
risk items
• Importer and exporter or consignee
• Notification parties
• Other trade parties: Insurance company, agents,
brokers, freight forwarder and carrier, shipping company,
intermediaries
• Customer: Name(s) and beneficial owners
