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...
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...