How Often Should You Screen Customers for Sanctions?

Start with onboarding screening

For relationships where sanctions exposure is relevant, screening before establishing the relationship or completing a transaction can prevent an avoidable problem. The timing should give the business enough opportunity to investigate a possible match before value is transferred.

Do not assume onboarding is enough

Sanctions programs and lists change. A customer who was not listed when onboarded can later become designated, and a business relationship can change in ways that create new sanctions risk. OFAC has specifically warned in its published guidance that controls that were adequate at one point may not remain adequate after sanctions change.

Use event-driven rescreening

A strong program identifies events that should trigger a new check rather than relying exclusively on a calendar.

• OFAC or other applicable sanctions-list updates
• Material customer-information or ownership changes
• A new beneficiary, counterparty, or related party
• A higher-risk transaction or new geography
• Account or contract renewal
• A previously unresolved or newly relevant alert

Choose periodic screening based on risk

OFAC's public guidance says screening frequency should be guided by the organization's policies and risk. Higher-risk businesses or relationships may justify more frequent screening than low-risk, occasional relationships. The written program should explain the chosen approach instead of using an arbitrary frequency with no connection to risk.

Make list updates operational

If a screening provider refreshes sanctions data automatically, the business should still understand how those updates affect existing customers. Ask whether existing records are automatically rescreened, whether alerts are generated, and how quickly staff are expected to adjudicate them.

Document your rescreening policy

Write down who is screened, which lists are relevant, when screening occurs, what events trigger rescreening, who reviews alerts, and how decisions are retained. A consistent, documented process is easier to operate and defend than an informal practice known only to one compliance employee.

How PeakAML can support the process

PeakAML can help businesses run supported sanctions screening and retain the evidence of reviews. Your organization remains responsible for setting an appropriate screening frequency and escalation process based on its sanctions exposure and applicable requirements.