What are sanctions checks?
Sanctions checks screen customers and transactions against lists of individuals, entities, and countries that are legally prohibited from receiving financial services.
Sanctions are restrictions imposed by governments (UN, Australia, US, EU) to prevent financial support of terrorism, corruption, and other serious threats. You must screen customers to avoid severe penalties.
Important: Sanctions violations can result in up to 10 years imprisonment and millions in fines.
easyAML automatically scans sanction lists for you as part of the Customer Due Diligence process.
What are sanctions?
Legal restrictions prohibiting business with:
- Specific individuals (terrorists, corrupt officials, human rights abusers)
- Entities and organizations (terrorist groups, shell companies)
- Countries or regions (embargoed nations)
Who imposes them?
- United Nations (UN) - Binding on Australia
- Australian Government - DFAT Consolidated List
- International - US (OFAC), EU, UK (may apply to your business)
What to Do If You Find a Match
If you confirm a sanctions match:
- Stop immediately - Do not proceed
- Do not tip off the customer
- Report to authorities:
- Australian Federal Police (AFP)
- AUSTRAC if suspicious activity involved
- DFAT for sanctions guidance
- Seek legal advice
- Document everything
- Freeze assets under your control
What NOT to do:
- Ignore potential matches
- Notify the customer you're screening them
- Proceed with "just one transaction"
- Fail to document your decisions
Common Questions
Do I need to check every customer? Yes. All customers must be screened at onboarding minimum.
What if my customer does business in a sanctioned country? Requires enhanced due diligence. Ensure you're not indirectly facilitating sanctioned activities.
Can I rely on my bank's screening? No. You have an independent obligation to conduct your own screening.
What if sanctions change after onboarding? Ongoing screening is required. If a customer becomes sanctioned, cease the relationship immediately and report it
Need to conduct sanctions screening? easyAML's integrated screening checks multiple lists automatically and alerts you to any matches.
Questions about a potential match? Contact your compliance adviser or legal counsel for guidance on specific cases.
Remember: Sanctions compliance is not optional. When in doubt about a potential match, seek professional advice before proceeding.