Why Ongoing Sanctions Re-Screening Matters, Not Just Onboarding

Many DNFBPs treat sanctions screening as a one-time onboarding step. In practice, UN, OFAC, EU and UAE sanctions lists are updated frequently, and a customer who was clear six months ago may not be clear today. Best practice is to re-screen existing customers, beneficial owners and counterparties on a recurring basis — not just when a new relationship begins. This is especially important for higher-risk customer segments and for jurisdictions or individuals connected to CAHRA (Countries with AML/CFT deficiencies). A practical starting point: re-screen your full customer book at least quarterly, and immediately after any major sanctions list update is issued. Document each screening run, even when the result is clear, so you can demonstrate ongoing due diligence to your regulator.