Most firms can show that every new client was screened before the account opened. Fewer can show when an existing client was last screened, against which version of the UK sanctions list, and who cleared the result. That gap is where real exposure tends to sit...
There is a difference between running checks and completing a verification. Most programmes do the former: an identity check here, a sanctions screen there, an ownership search when someone asks. Fewer can show the latter, a single documented decision that a reviewer...
In most firms, PEP screening and sanctions screening grew up separately. They run against different lists, often on different schedules, sometimes owned by different teams. Yet the exposure they are looking for frequently runs through the same individuals: the...
Typing a name into a search engine and finding nothing alarming is not a due diligence check. It is the absence of a result, which is a different thing entirely. A clean first page reflects what a public crawler has indexed and ranked, not what licensed registries...
Customer due diligence works only when the depth of effort is proportional to the risk in front of the analyst, but in practice many programmes drift toward a single uniform process because tiering rules are unwritten or inconsistently applied. The intent is rarely...
A retired backbench MP in a standard-risk jurisdiction and a sitting foreign head of state are both politically exposed persons under current regulatory definitions. They do not present the same risk. Yet many compliance teams apply effectively the same screening...