SANCTIONS SCREENING PROCEDURES & ESCALATION PLAYBOOK

2026 Edition | Compliance Consultant — Making Compliance Work

OFSI enforcement is intensifying. In 2025, penalties totalling approximately £500,000 were imposed across multiple enforcement actions — and proposed reforms would double maximum penalties to £2 million. Under the strict liability regime, your firm can be penalised regardless of intent.

Can you demonstrate documented, robust sanctions screening procedures and defined escalation pathways?

This Playbook gives you everything you need to build, implement, and evidence a professional sanctions screening framework that meets the expectations of OFSI, the FCA, and SMCR accountability requirements.

WHAT'S INCLUDED:

Complete Sanctions Screening Methodology

• Step-by-step screening procedures covering all trigger points (onboarding, transactions, periodic reviews, event-driven rescreening, OFSI alert response)
• Screening parameter guidance including fuzzy matching thresholds, name transliteration, and alias matching
• 3-category match assessment framework (False positive / Possible Match / Confirmed Match)
• Enhanced assessment procedures for Level 2 review

4-Tier Escalation Framework

• Defined escalation tiers with clear triggers, responsibilities, and timescales
• Confirmed match escalation procedure (8-step protocol from freeze to ongoing monitoring)
• OFSI breach reporting guidance and preparation checklist
• OFSI licensing application guidance

Ready-to-Use Templates

• Sanctions Screening Record template
• Sanctions Match Confirmation & Escalation Record template
• OFSI Breach Report Preparation Checklist
• Ownership & Control Assessment template
• Sanctions Risk Assessment template
• Screening system performance monitoring metrics
• Training record template

Comprehensive Regulatory Framework

• Full coverage of SAMLA 2018, OFSI Guidance, MLRs 2017, FCA SYSC & Financial Crime Guide
• Updated for the UK Sanctions List (UKSL) transition from 28 January 2026
• Strict liability standard explained with practical implications
• Criminal offences overview (up to 7 years imprisonment)

Red Flags & Sanctions Evasion Typologies

• Customer & counterparty red flags
• Transaction red flags
• OFSI-identified evasion typologies (from the February 2025 Financial Services Threat Assessment)
• Intermediary jurisdiction risks

Governance, Training & Record-Keeping

• Roles and responsibilities matrix (Board to Level 1 Screeners)
• Training requirements framework by audience
• Record retention requirements (5-year minimum)
• Annual review and event-driven review governance

WHO IS THIS FOR?

1. Compliance Officers & Sanctions Officers
2. MLROs & Deputy MLROs
3. Senior Managers under SMCR (SMF16 / SMF17)
4. Investment firms, payment institutions, EMIs, consumer credit firms, insurance intermediaries
5. Internal Audit & Risk Assurance teams
6. Any UK FCA-regulated firm seeking to strengthen its sanctions screening procedures

FORMAT: Professional Microsoft Word (.docx) document — fully customisable with your firm's name, branding, and specific procedures.

Instant digital delivery. Implement within days.

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