Sanctions Screening

Last reviewed: · Curated by Ohmyfin Organisation editorial.

Sanctions screening is the regulatory process of checking every cross-border payment's sender, beneficiary, banks and references against international sanctions lists (OFAC, EU, UN, HMT and dozens more) before releasing the funds. Pre-screen a counter-party free → · Track your payment →

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Details

Every correspondent bank in the chain runs its own independent sanctions screening — not just the sending and receiving banks, but every intermediary too. The screening checks names, addresses, and account numbers of the ordering customer, the beneficiary, and the banks themselves against multiple lists simultaneously: the US OFAC SDN (Specially Designated Nationals) list, the EU Consolidated List, UN Security Council sanctions lists, UK HMT consolidated list, and potentially dozens of other national and sectoral lists depending on the currency and the correspondent's jurisdiction. A positive or near-positive match triggers an alert that pauses the payment while a compliance analyst investigates.

Even a "fuzzy" match — where a beneficiary's name bears only a partial resemblance to a sanctioned individual, company or entity — can trigger a hold. Banks tune their screening sensitivity based on their risk appetite and regulatory guidance. More sensitive tuning catches more real violations but creates more false positives. False positives can delay an innocent payment by hours or days while a compliance officer reviews the alert. For payments to higher-risk countries or currencies, screening can take 24–72 hours even if the payment is entirely legitimate.

On the SWIFT GPI tracker (visible on Ohmyfin), a sanctions screening hold typically shows as ACWP (accepted with pending change). This means the payment has been accepted and is being held pending a compliance decision. Some banks leave the payment in ACSP (accepted, settlement in progress) for an extended period during a screening hold without updating to ACWP, which can be difficult to interpret. If your payment has been in ACSP for more than 24 hours on a major corridor, a sanctions hold is a likely explanation.

Senders can reduce sanctions screening delays by: (1) Using the most complete and accurate beneficiary data possible — full legal name matching identity documents, complete structured address, and the beneficiary's national ID or company registration number where MT103 field 50F or pacs.008 structures support it. (2) Providing clear, unambiguous remittance information in field 70 — avoid country names or terminology that pattern-matches against watchlists. (3) Pre-screening the beneficiary against major sanctions lists before sending — Ohmyfin's free check at /sanctions covers OFAC, EU and UN lists in real time.

Banks that violate sanctions face severe consequences. OFAC can impose civil penalties of up to $1.5 million per violation or twice the transaction amount, whichever is larger. Criminal penalties can reach 20 years' imprisonment. Landmark enforcement actions include Standard Chartered ($1.1 billion, 2019) and HSBC ($1.9 billion, 2012). These consequences explain why banks are extremely cautious about sanctions screening, even at the cost of customer inconvenience.

Key facts

Frequently asked questions

Why is my payment stuck in sanctions screening?

A name, address, BIC or reference in the payment matched or partially matched a sanctions-list entry. The correspondent bank's compliance team must clear the alert manually before the payment proceeds. This can take hours to several days depending on the complexity of the match.

How can I speed up a payment held for sanctions?

Contact your sending bank and ask them to escalate to the holding correspondent's compliance team. Providing additional documentation (a photo ID or company registration certificate for the beneficiary) can help clear the hold faster. On Ohmyfin you can see which specific bank is holding the payment — ask your bank to contact that institution directly.

What is OFAC and why does it matter?

OFAC (Office of Foreign Assets Control) is a US Treasury agency that administers US economic sanctions. Every bank anywhere in the world that processes USD payments must comply with OFAC — because USD transactions ultimately clear through US correspondent banks subject to US jurisdiction. This gives OFAC global reach even over non-US banks.

Can I pre-screen a beneficiary before sending?

Yes — Ohmyfin's free sanctions check at /sanctions checks the beneficiary's name against the OFAC SDN List, EU Consolidated List, and UN Consolidated List in real time. A clean result does not guarantee the payment will not be held (banks have their own internal watchlists), but it significantly reduces the risk of the most common screening failures.

What is a false positive in sanctions screening?

A false positive occurs when a payment is flagged even though neither the sender nor the beneficiary is actually sanctioned. This happens when a name or address partially matches a sanctioned entity. For example, a beneficiary named "Ali Hassan" might partially match a sanctioned individual with a similar name. Human review is needed to clear the alert before the payment can proceed.

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