Sanctions Screening Programme

Sliding Line

  • Exevion was brought in by a consolidator in the Wealth Management sector to improve their Sanctions Screening process.

    Thousands of Sanctions Lists are published by national governments or groups like the UN, which detail individuals or entities that businesses should not trade with. These cover a wide variety of people and entities, from Russian Oligarchs to individuals associated with the Islamic State. Lists are updated frequently and at short notice.

    Sanctions Screening is the process businesses are required to follow, which confirms that they are not doing business with the individuals or entities on a Sanctions List. For our client, this meant:

    • Ensuring that they weren’t allowing payments to be made to individuals or entities on a Sanctions List;

    • Ensuring that businesses on their client list were not included on a Sanctions List;

    • Ensuring that securities they were being instructed to trade were not under sanctions.

    The client had an existing screening process, but as the scale of the business grew, they wanted to enhance it to strengthen compliance with a proportionate level of screening tools and procedures.

  • Exevion led and delivered the project from initial scope definition to completion. This included creating detailed process documentation, running a vendor selection process and managing the implementation.

    • As-Is Documentation: produced detailed documentation of the existing screening process, creating a comprehensive overview that served as the baseline for evaluation and to build a gold standard process from. This documentation was pivotal for both internal understanding and external communication, demonstrating the robustness of the new process.

    • Vendor Selection: conducted a detailed vendor evaluation process, aligning each selection with project requirements and overarching business objectives. 3 vendors were chosen, with each one contributing to a component of the proposed solution.

    • Contract Negotiation: negotiated with selected vendors to secure contracts and statements of works which aligned with project specifications and the client’s wider strategic objectives. This included agreeing on detailed implementation approaches and a cross-vendor RACI.

    • Implementation: managed the delivery of the planned screening enhancements, prioritising a long term gold standard screening process throughout the roll-out. This minimised disruption to existing operations in the short and long term.

    • Reporting: ensured visibility of key project objectives, planned approach and completed activities towards project implementation. This meant that internal stakeholders and 3rd parties had visibility of the project’s progress.

  • We delivered a successful screening programme, which resulted in the following:

    • The introduction of an automated 3 lines of defence screening process for the business;

    • The selection and contracting of 3 vendors to deliver technical aspects of the solution, negotiating over £100K of savings;

    • Detailed documentation of the new processes for business as usual operation;

    • Performance monitoring in place to improve screening accuracy and reduce workload on compliance and operations teams.

  • Delivering programmes of work that affect a wide range of functions requires sufficient buy-in from across the business. Engaging people and giving visibility to the decision-making process is important to achieve this.

    This was a key contributor to the project’s success, and we used it throughout to help keep the new process being designed and implemented aligned with the gold standard agreed in the first project phase.

    At Exevion, we have extensive experience managing operations projects and implementations across a range of industries, and would love to hear how we can help you.