How are sanctions, politically exposed persons, and international counterparties screened?
We screen clients, owners, counterparties, payees, and relevant transactions against current sanctions lists and risk databases. Potential matches receive manual review using identifiers such as date of birth, nationality, ownership, and address. Politically exposed persons receive risk based enhanced due diligence. International relationships may require additional documents, ownership checks, and source of funds information.
Sanctions screening
For relationships and transactions subject to applicable sanctions requirements, we screen new clients, beneficial owners, counterparties, payees, and relevant transactions against applicable sanctions lists. OFAC describes a tailored, risk based compliance program that may include sanctions list screening. Its lists include identifying details such as aliases, nationality, date of birth, identification numbers, and addresses. A name alert is only a lead. We compare available identifiers and investigate whether it is a true match or a false positive. OFAC sanctions FAQ OFAC matching guidance
Screening continues after onboarding. The UK Financial Conduct Authority recommends screening customers, counterparties, and payments when relationships begin, and rescreening when lists or customer details change. We document alerts, decisions, and escalation steps. A possible match is held for review until the relevant facts are clear. FCA sanctions guidance
Politically exposed persons
A politically exposed person, or PEP, is someone who holds or has held a prominent public role. The review also considers relevant family members and known close associates. Guidance for private banking relationships involving senior foreign political figures calls for reasonable identification steps and enhanced due diligence. A PEP designation is a risk signal, not proof of wrongdoing or a sanctions match. FinCEN beneficial ownership guidance
Our review may seek information about the person’s role, ownership interests, source of wealth, and source of funds. We then set monitoring and approval steps that fit the facts and risk. We record why the relationship was accepted, limited, or escalated.
At the very least, most single family offices should be conducting 40 hours of due diligence, background checks, reference checks, and fact-gathering practices before making an investment.
International counterparties
For an overseas company, lender, broker, administrator, or payment recipient, we identify the legal entity, ownership, control, jurisdiction, business purpose, and people involved in the transaction. We check the entity and relevant individuals against sanctions lists, then investigate ownership or control links that may create sanctions exposure. Regulators emphasize screening counterparties and payments, with controls proportionate to the firm’s risk. FCA sanctions systems guidance
Higher risk cases can require incorporation records, ownership charts, licenses, banking details, contracts, and source of funds evidence. If information is incomplete or inconsistent, we pause the relationship or transaction while compliance reviews the facts. This page is educational and does not provide legal, tax, or investment advice.
Related guides
- Family Office Due Diligence: A Practical Guide for Multifamily Offices
- Access to Alternatives Through an MFO: A Practical Guide for Families
- Cross-Border Families and Multifamily Offices: A Practical Guide
Sources
- OFAC FAQ 445, compliance obligations and risk based screening
- OFAC FAQ 5, evaluating potential sanctions matches
- FCA Handbook FCG 7, screening customers, counterparties and payments
- FinCEN, Guidance on Obtaining and Retaining Beneficial Ownership Information
- FCA, Sanctions systems and controls in our firms