The Clients Team undertakes sanctions screening as part of the Firm's onboarding procedures. The Firm includes the UK Sanctions List, OFAC Consolidated Sanctions List, EU Sanctions List and UN Consolidated Sanctions list in its conflict checking database. Clients also undergo sanctions screening through Accuity and Credas as part of the client onboarding process. The Firm also conducts risk-based searches of its client and matter records when relevant new sanctions or restrictions come into force. Potential matches will be investigated and may result in additional enquiries, restrictions on work, suspension of activity or termination of the instruction, to the extent permitted by law and professional obligations.
However, sanctions compliance depends on more than screening results.
You must ensure you understand:
You should not assume that a clear screening result means a matter is automatically capable of proceeding. Sanctions screening is therefore both an onboarding and an ongoing control. You must tell the MLRO promptly if you become aware of any new party, owner, controller, asset, vessel, jurisdiction, payment route or activity that may alter the sanctions assessment.
As with all financial crime controls, professional judgement remains essential.
An unresolved potential sanctions match must not be treated as cleared. No affected work or movement of funds may proceed until the match has been investigated and the Clients Team or MLRO confirms the applicable position.