Category: Screening

Having the right lists is only half the problem. The other half: the half that generates regulatory penalties, correspondent banking consequences and reputational damage is whether the screening programme actually works when it needs to. Most sanctions screening failures are not caused by institutions that didn’t know the obligation existed. They are caused by institutions […]

Compliance officers in India’s financial sector are familiar with the idea of screening customers against lists. What is less consistently understood is that not all screening obligations carry the same legal weight – and that confusing a risk-based due diligence requirement with an absolute statutory prohibition can quietly undermine how an institution designs, resources and […]