Sanctions screening is a critical component of Anti-Money Laundering (AML) compliance, ensuring that organisations do not inadvertently interact with restricted parties or facilitate illegal activities.

In 2024, as global and national security threats evolve, maintaining an effective sanctions screening process is more important than ever.

Sanctions can be defined as penalties or restrictive measures imposed by sanctioning bodies such as governments or international bodies like the United Nations. These measures target entities, individuals, countries, and even vessels to achieve objectives like curbing terrorism, enforcing political change, or preventing financial crime.

Sanctions screening refers to the systematic process of checking individuals, entities, or financial transactions against sanction lists to ensure compliance with regulatory requirements.

What are sanctions lists?

Sanctions lists are compilations of individuals, entities, and countries subject to sanctions. Commonly used lists include the Office of Foreign Assets Control (OFAC) list in the United States, the EU Consolidated Financial Sanctions Lists, and the UK Sanctions List.

These lists are maintained by various sanctioning bodies and are regularly updated to reflect changing geopolitical and regulatory landscapes.

Organisations must use robust sanctions screening software to monitor these lists effectively, ensuring compliance and safeguarding their operations from legal and financial repercussions.

Sanctions regulations and regulatory bodies

Sanctions screening is mandated by several regulatory bodies worldwide. Financial institutions and businesses must comply with regulations set by organisations like the Office of Foreign Assets Control (OFAC), the UK Financial Conduct Authority (FCA), and the European Banking Authority.

The primary aim of these regulations is to prevent businesses from engaging with sanctioned individuals and entities or facilitating transactions that compromise national security or infrastructure. For example, sanctions often target terrorist financing, human rights abuses, or weapons proliferation.

Recent updates in sanctions compliance highlight the need for enhanced automation and accuracy in the process. With geopolitical tensions rising, 2024 has seen a greater emphasis on the integration of AML software solutions and real-time monitoring of sanctions data.

Types of Sanctions

Sanctions are diverse, and businesses must understand their scope and impact to comply effectively.

Economic sanctions ‍

• Aim to restrict access to financial resources
• Target sanctioned parties, including individuals, organisations, and governments.
• Often involve freezing foreign assets or restricting financial transactions.

Trade sanctions

• Impose restrictions on importing or exporting goods and services to specific regions.
• Designed to disrupt economic systems of sanctioned entities while maintaining broader market stability.

Travel bans

• Prevent entry or transit of specific individuals across international borders.
• Often applied to Politically Exposed Persons (PEPs) involved in corruption or criminal activities.

Implementing Sanctions Screening

Sanctions screening is a vital compliance process that requires a structured approach. Below are the key steps, providing greater detail and actionable insights:

Identifying Relevant Sanction Lists

• Sanctions lists vary depending on the jurisdiction and the nature of your business operations. Identifying which lists to monitor is the foundation of an effective sanctions screening program.
• Global sanctioning lists include those maintained by the United Nations, European Union, and the Financial Action Task Force (FATF).
• National sanctioning bodies maintain specific lists, such as the Office of Foreign Assets Control (OFAC) in the U.S. and HM Treasury's Office of Financial Sanctions Implementation (OFSI) in the UK.
• Businesses operating across borders may need to monitor multiple lists simultaneously to avoid compliance gaps.

Screening Customers and Transactions

• Screening involves checking individuals, entities, and transactions against identified sanction lists. This step is crucial to prevent unintentional engagement with sanctioned parties.
• Customer screening typically occurs during the Customer Due Diligence (CDD) phase, ensuring no red flags are associated with a prospective client.
• Transaction screening focuses on verifying that financial transfers or trade dealings do not involve sanctioned entities. Real-time transaction monitoring is essential for high-risk industries like financial services and international trade.

Verifying Matches

• Not all flagged names or entities are genuine matches; some are false positives resulting from similar names or incomplete data. Verifying matches requires a rigorous investigation process.
• Contextual analysis helps differentiate true matches from false positives by cross-referencing additional details, such as nationality, date of birth, or company affiliations.
• Some advanced screening software solutions incorporate artificial intelligence (AI) to reduce false positives by improving data accuracy and match reliability.
• Clear escalation protocols should be in place for handling potential matches, ensuring that compliance officers can act promptly and effectively.

Maintaining Records

• Comprehensive record-keeping is a regulatory requirement and a best practice for businesses. This step ensures transparency and prepares organisations for potential audits or investigations.
• Maintain a log of all screening activities, including customer data, flagged matches, and resolution outcomes.
• Ensure that records are securely stored and easily accessible, in line with data protection regulations like the General Data Protection Regulation (GDPR) in the EU or similar national laws.
• Periodically review records to identify trends or recurring compliance issues that may require process adjustments.

Updating Screening Practices

• Sanctions lists are dynamic, with frequent updates reflecting geopolitical changes, new legislation, or emerging risks. Keeping screening practices current is vital for ongoing compliance.
• Implement systems that allow for automatic updates to sanctions lists. This reduces the risk of missing new entries or changes in existing listings.
• Regularly audit your screening tools to ensure they are capturing all necessary data and functioning as intended.
• Stay informed about changes in regulatory frameworks, such as updates to foreign assets control policies, by subscribing to updates from relevant regulatory bodies.

Integrating Sanctions Screening with AML Processes

• Effective sanctions screening does not exist in isolation—it should be integrated seamlessly with your organisation’s AML software solutions and compliance processes.
• Coordinate sanctions screening with Know Your Customer (KYC) protocols to ensure comprehensive due diligence at every stage of the customer relationship.
• Use unified platforms to consolidate AML, KYC, and sanctions screening activities, minimising operational silos and enhancing efficiency.
• Collaborate with compliance specialists to design workflows that align with both legal obligations and your organisation’s risk appetite.

What is sanctions screening software?

The complexity of sanctions screening necessitates the use of sanctions screening software. Such tools automate the process, providing efficiency, accuracy, and scalability. Features of robust screening software include:

• Real-time monitoring: Immediate detection of changes to sanction lists.
• Comprehensive integration: Seamless compatibility with AML and Know Your Customer (KYC) systems.
• High-quality data: Ensures data quality for effective decision-making.
• Customisable filters: Allow businesses to focus on relevant risks specific to their operations.

Sanctions challenges

Sanctions screening, even with the addition of automated software, is not without its challenges. Businesses looking to implement advanced screening face several hurdles, including:

High false positive rates

Common in traditional systems, leading to unnecessary resource expenditure.

Data quality issues

Inconsistent or outdated data can compromise the screening process.

Evolving regulatory requirements

Adapting to frequent updates from regulatory bodies demand agile systems to balance complexity.

Integration with existing systems

Ensuring smooth integration with financial services tools for a full CDD stack.

It is also critical to evaluate your sanctions screening process to ensure it meets modern compliance standards and cross-jurisdictional complexity. Sanctions screening is not a one-time task; it’s an ongoing commitment. Businesses must routinely evaluate their systems to address inefficiencies and ensure alignment with global and local regulations.

Sanctions screening is more than a regulatory requirement, it’s a fundamental part of operating ethically and securely in today’s interconnected world. By understanding what sanctions screening is, implementing effective processes, and leveraging advanced tools, businesses can confidently navigate the complexities of modern compliance.

How FullCircl can help

For organisations looking to streamline their compliance processes, FullCircl provides industry-leading solutions tailored to the needs of regulated businesses. From advanced sanctions screening to comprehensive AML, KYC, and KYB compliance, FullCircl ensures your organisation stays protected and efficient.

Take the proactive step toward robust compliance today. Explore FullCircl’s solutions to safeguard your operations and build trust with your clients. Reach out to the team today to see the software in action.

Psst… did you hear that nCino and FullCircl have merged?

In October we signed a definitive acquisition agreement. Now we’d like to invite to celebrate this exciting new chapter with us, as together we work to break down barriers in banking.

Join us for an unforgettable Christmas lunch overlooking the iconic St Paul’s Cathedral and get an exclusive deep dive into our collaboration. Learn why this is a partnership set to redefine client lifecycle management in banking, by seamlessly integrating client acquisition, onboarding due diligence, compliance checks and rules-based monitoring.

What’s on the menu?

Other than a carefully crafted festive menu, fine wine, and great company, you’ll get an exclusive first look at the what, the why, and the how of our ground-breaking partnership:

• Why we merged
• What it means for you
• How we’ll help you drive growth

End the year with some festive cheer on us

Date: 10^th December2024

Time: 12:00-14:00hrs

Location: The Happenstance, 10 Paternoster Square, London, EC4M 7DX

RSVP to robert.taylor@fullcircl.com to express your interest. We hope to see you there!

We spoke to FullCircl partner AAZZUR about how they approach compliance, empowering their clients to balance speed and regulatory adherence to deliver an output of enhanced growth.

In today’s fast-paced world of wealth management, delivering a seamless customer experience while meeting strict regulatory standards is crucial. As we progress through 2024, the need for speed and compliance has never been more pressing. That’s where AAZZUR steps in, revolutionising how Know Your Customer (KYC) and Anti-Money Laundering (AML) processes are handled without compromising on onboarding or regulatory requirements.

In partnership with FullCircl, we’re taking customer experience to the next level. Our technology ensures faster, smoother, and fully compliant onboarding for clients and enterprises alike. Here’s how we’re making it happen.

Balancing Speed and Compliance in Wealth Management

Let’s face it—no one enjoys a slow onboarding process, especially in wealth management. Clients expect quick, seamless access to services, whether they’re opening an investment account or starting a financial advisory relationship. With tightening regulations around KYC and AML, wealth managers often struggle to maintain this balance. That’s where AAZZUR’s solutions come in, ensuring that onboarding stays fast and efficient without cutting corners on compliance.

The Power of Hybrid Solutions

We know that not all clients have the same risk profile. Some glide through basic KYC and AML checks, while others—such as politically exposed persons (PEPs) or high-net-worth individuals—require enhanced due diligence. Our hybrid approach combines automation for low-risk clients with manual intervention for complex cases. This flexibility ensures compliance while providing a frictionless client experience.

Flexibility in KYC for Better Client Experiences

Here’s the game-changer: choice. With AAZZUR’s flexible approach, wealth managers can offer clients options for identity verification, whether it’s through biometrics, digital IDs, or traditional document uploads. This customisation caters to a range of client preferences, boosting satisfaction and reducing onboarding friction.

Leading the Way in 2024

At AAZZUR, we’re turning compliance from a tick-box exercise into a fundamental part of a great client journey. By merging automation, personalisation, and unwavering compliance, we’re paving the way for wealth managers to thrive. Our collaboration with FullCircl helps power this transformation, creating a seamless ecosystem for firms to operate efficiently and compliantly.

Curious about what’s next? Stay tuned as we continue to lead the charge in reimagining compliance for the modern financial landscape.

Find out more about AAZZUR here.

Guide to KYC Solutions and Compliance

Know Your Customer (KYC) regulations and processes are critical to ensuring safe and compliant interaction between financial institutions and their customers. These regulations not only protect businesses and individuals from financial crime, but they also establish trust and transparency in a competitive market.

By focusing on robust KYC solutions, organisations can safeguard themselves against risks like identity fraud, money laundering, and other financial crimes.

This guide provides an in-depth look at KYC solutions, covering essential processes, requirements, and the role of automation in a rapidly evolving field.

‍What is KYC

Know Your Customer, better known by its acronym KYC, is a regulatory standard implemented globally to verify the identity of customers, assess their risk, and monitor their ongoing activity.

Initially popularised within the banking sector, KYC has become a crucial compliance measure across financial services, insurance, gambling, ecommerce, and beyond.

The key goal of KYC is to confirm that the person trying to open an account is who they say they are, and this can be broken down into three key areas:

• Customer identification and verification: Verifying the identity of each customer to prevent fraud.
• Customer Due Diligence (CDD): Conducting in-depth analysing of each customer’s background to assess risk. Enhanced Due Diligence (EDD) can also be deployed dependent on level of customer risk.
• Ongoing monitoring: Continuously tracking customer activity to identify unusual or suspicious transactions.

The components collectively create a secure and transparent financial environment, deterring financial crime and ensuring compliance with regional and global regulatory requirements.

KYC Solutions: Identification, CDD, and Ongoing Monitoring

KYC solutions consist of several interconnected processes designed to authenticate and monitor customer information accurately. Here’s an overview of the main KYC solutions:

Identification and Verification

This is a foundational step in the KYC process, consisting of collecting legal name, address, and / or government issued ID, to ensure that the person is who they claim to be. Reliable identity verification methods protect against theft and fraud.

‍Customer Due Diligence (CDD)

This process follows directly from identification and verification and with the addition of automated solutions, both processes can be done in tandem. During CDD, businesses will assess customer risk through a deeper analysis of their financial background and risk profile. CDD ensures that high-risk customers are identified early, allowing organisations to apply additional scrutiny including Enhanced Due Diligence (EDD) as needed.

Ongoing Monitoring

Sometimes referred to as perpetual KYC, ongoing monitoring is a continuous process of observing and analysis customer activity. By identifying unusual behaviours through services such as transaction monitoring or being notified of any changes to customer risk including becoming a PEP, sanctioned, or new adverse media, businesses can address potential risks proactively.

‍What are KYC Requirements & Regulations?

KYC requirements are detailed guidelines set by regulatory authorities to ensure customer verification and Anti-Money Laundering (AML) compliance. While these standards are designed to reduce financial crime, specific requirements vary widely depending on the sector, jurisdiction, and regulatory body involved.

Sector specific regulations

Financial institutions, gambling operators, insurance firms, and payment providers are often subject to stringent KYC requirements due to their vulnerability to financial crime, fraud, and money laundering. Regulations including the UK Gambling Act, The Consumer Duty, and the 6^thAnti-Money Laundering Directive are designed to regulate industries specifically.

‍Multi-jurisdictional complexity

KYC for banks and other global financial institutions becomes more complex in multi-jurisdictional setting, where each country’s regulations may vary. For example, while the US primarily follows the Bank Secrecy Act (BSA), the EU, as mentioned, has its Anti-Money Laundering Directives (AMLD) and other guidelines. Harmonising processes to comply with nuances in regulation requires meticulous planning and often the assistance of KYC software tools.

Ongoing adaptations

As financial crime evolves, regulatory requirements are set to adapt and become more stringent to maintain security. Regulated entities are expected to stay updated on regulatory changes, ensuring that their KYC processes meet all current compliance needs.

The Future of KYC

The future of KYC will likely be defined by automation, artificial intelligence, and blockchain technology, which are reshaping how businesses do compliance. These advancements promise to enhance the efficiency and accuracy of the KYC process.

1. Automated Id Identification and Verification: Automation allows for faster and more accurate customer identification, reducing the manual workload on compliance teams. It also minimises human error and accelerates onboarding, enhancing the customer experience.
2. AI and Machine Learning: AI technologies can analyse customer data at scale, identifying patterns and anomalies in real time. This capability strengthens the ongoing monitoring process by predicting suspicious activity before it escalates.
3. Blockchain for Enhanced Transparency: Blockchain technology enables secure and tamper-proof record-keeping, which could significantly reduce fraud and enhance trust in identity verification.

Using KYC Software and Automation Tools  

Adopting KYC software solutions can simplify compliance by automating key components of the KYC process. Today’s solutions offer a range of capabilities, including automated identity verification, customer information management, and regulatory reporting.

Benefits of KYC Software:‍

• ‍Increased Efficiency: Automation tools streamline the KYC process, allowing for quicker customer verification and onboarding.‍
• Reduced Compliance Costs: By minimising the manual workload, businesses can reduce operational costs and allocate resources to higher-value tasks.‍
• Enhanced Accuracy and Reporting: Automation tools ensure compliance by staying updated with regulatory changes, thereby reducing the risk of human error.

Examples of KYC Software Capabilities:‍

• ‍Perpetual KYC: Automatically updating customer records to reflect any changes in risk status.‍
• Comprehensive Documentation Management: Safely storing and managing KYC documents for audit purposes.

‍Get Started with FullCircl KYC Solutions

For businesses seeking to protect themselves from financial crime and ensure regulatory compliance, adopting a robust KYC solution is essential. FullCircl offers a comprehensive suite of IDV solutions designed to simplify customer identification, enhance customer due diligence, and maintain ongoing monitoring. With FullCircl, businesses can access cutting-edge tools that streamline the KYC process, reduce compliance costs, and enhance their ability to respond proactively to regulatory changes. Contact the team here to find out more.

Want to learn more about the latest identity verification and KYC trends? Download FullCircl's State of IDV Report to prepare for 2025.

Regulation Update: New Guidance for Implementation of Companies House Reforms

The Economic Crime and Corporate Transparency Act (ECCTA) came into force 12 months ago with the aim of strengthening the UK’s efforts to combat economic crime via a wide-ranging suite of reforms.  

Importantly the Act gives Companies House new and enhanced powers to scrutinise information provided by companies and their directors, turning it from a largely passive recipient of company information to a much more active gatekeeper.  

Background to the Companies House Reforms

Companies House now has enhanced abilities to verify the identities of company directors, remove fraudulent organisations from the register, and share information with criminal investigation agencies.  

This will serve to drive greater trust in UK companies both domestically and internationally.  The primary benefits of more accurate and reliable information in the register are that companies can better assess the risks posed by potential customers, business partners and suppliers, and reduce the incidence of fraud, money laundering and other types of financial crime.

However, some have viewed the reforms as a burden both in times of cost and resource, in particular the increased reporting requirements around beneficial ownership and identity verification of directors, shareholders, persons with significant control, and other agents.

Companies House has published a transition plan to assist companies in preparing for the changes. It outlines the timeline for the commencement of key provisions of the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023).

‍Outline plan for phased implementation of Companies House reforms

By the end of 2024/early 2025 Companies House will be able to:

• Issue financial penalties for any relevant offences under the new Act and the Companies Act
• Expedite the striking off of companies where the registrar has concluded the company has been formed for a false basis
• Annotate the register in a wider range of circumstances, such as when a company has a director who has been disqualified but has yet to terminate their appointment on the register, or where Companies House has issued a statutory notice to require more information from a person, but the matter remains unresolved

‍

Spring/Summer2025 this will be expanded so that Companies House can:

• Carry out checks on Authorised Corporate Service Providers (ACSPs) to authorise them to carry out verification services – ACSPs will be required to be registered in the UK and be subject to the UK’s anti-money laundering regime
• Allow individuals to voluntarily verify their identity
• Receive and assess applications from individuals seeking to have residential addresses suppressed from public disclosure in certain circumstances
• Allow access on request to certain trust information on the Register of Overseas Entities

‍

Then by autumn 2025 Companies House should be able to:

• Make identity verification a compulsory part of incorporation and new appointments for new directors and PSCs
• Begin the 12-month transition phase to require more than 7 million existing directors and PSCs to verify their identity – the identity verification will happen as part of the annual confirmation statement filing

‍

During 2026 a range of phased changes should empower Companies House to:

• Make identity verification of the presenters a compulsory part of filing any document
• Require third party agents filing on behalf of companies to be registered as an ACSP
• Reject documents delivered by disqualified directors as they will be prohibited from doing so, unless they are delivered by an ACSP for specified filings permitted by law
• Require all limited partnerships to submit more information, providing greater transparency for users of the register
• Complete the transition period for all individuals on the register requiring identity verification, and start compliance activity against those who have failed to verify their identity
• Facilitate greater cross-checking of information and data between Companies House and other public and private sector bodies

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The full plan can be found here.

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If you have questions about the Companies House reforms or the potential impact of the Economic Crime and Corporate Transparency Act, as well as how to stay ahead of implementation get in touch with a member of our team today.

As I write this, I find myself reflecting on the remarkable journey we’ve all been on. When Mike, Steve, and I founded the company, nearly two decades ago, we named our company Artesian, after a certain type of well that draws water from the ground using natural forces. We wanted to automate the extraction of value in much the same way, albeit from unstructured data from the web, social media and the news (when digital news was just getting going). What started as a business intelligence platform aimed at transforming how companies leveraged insights to have better conversations every day, became a platform that facilitates better decisions every day, something much bigger than we could have ever imagined.

A few years ago, we took a bold step acquiring and joining forces with Justin Fitzpatrick and the team at DueDil, pioneers in company intelligence and KYB. This move not only brought invaluable talent and technology into our fold, but it also set the stage for our rebrand to FullCircl - a name that embodies our mission to create a truly end-to-end customer lifecycle platform. More recently, the acquisition of W2 Global Data Solutions, working with Warren Russell and team, leaders in KYC and AML compliance, helped us strengthen our capabilities with the addition of onboarding orchestration, giving regulated companies a complete toolkit to identify, acquire, verify, onboard, and monitor customers seamlessly.

Today, I’m incredibly excited to announce another milestone in our journey: FullCircl is now part of nCino. This acquisition marks a pivotal moment for our company, and it’s an opportunity, I believe, will benefit every customer, employee, and partner.

Why nCino?

For those who may not know, nCino is the leading provider of intelligent, best-in-class banking solutions, providing financial institutions with a comprehensive platform that brings together people and data and enables financial institutions to enhance strategic decision-making, risk management, and customer satisfaction. Our relationship with nCino has been building since we formally partnered in 2023, working together to integrate FullCircl’s capabilities into their intelligent platform. During this time, it became clear that our combined strengths could offer something truly special to the financial services community.

Our shared customers - including some of the UK's leading financial institutions and innovative digital banks - are already seeing the benefits of this collaboration. By joining forces with nCino, we are now positioned to deliver even greater value, expanding the reach of FullCircl’s frontline, onboarding, due diligence, and risk monitoring capabilities across Europe.

What This Means for You, Our Customers

As a FullCircl customer, you can look forward to significant enhancements in the services we provide. Our powerful business-rules engine, developed through years of collaboration and input from industry pioneers, will be part of a global platform that simplifies the complexity of onboarding while helping to ensure regulatory compliance. Imagine faster onboarding, integrated workflows, and access to real-time business data - all within a single system of record that streamlines your entire customer lifecycle, from acquisition to ongoing monitoring.

The joint proposition between nCino and FullCircl is about more than just software integration; it's about transforming how you engage with your customers. Together, we will offer a solution that not only makes compliance easier but drives profitability and growth for your business.

For the financial institutions we share with nCino, this acquisition enhances our combined capabilities and empowers your teams with even more tools to serve your customers better, faster, and with greater transparency. The FullCircl platform will now be complemented by nCino’s global reach and resources, making it possible for us to deliver even more value to your business.

We remain deeply committed to serving our non-financial businesses across various industries including insurance, gaming tech and telco. Many of you have leveraged FullCircl's capabilities to enhance business development efforts, reduce risk exposure and understand your customers and markets in your own unique contexts. Rest assured, these offerings will continue to be an integral part of our solution portfolio, and we will maintain our focus on helping all our clients - whether financial or non-financial - achieve their growth and compliance goals.

A Message to Our Team

To the entire FullCircl team, I want to extend my deepest gratitude for your dedication, sacrifice and focus. From the early days of Artesian to the strategic acquisitions of DueDil and W2 Global Data, you have been the driving force behind our success. This acquisition is a testament to everything we’ve achieved together. And now, as part of nCino, we have the opportunity to make an even bigger impact, on a global scale.

Our work is far from over - this is just the beginning of a new and exciting chapter. nCino values the innovation and expertise that each member of our team brings, and together we will continue to move forward at pace, delivering more powerful functionality for the frontline, unique onboarding capabilities, smarter compliance, and solutions that accelerate growth for our customers.

The Road Ahead

This acquisition marks an important step in our shared journey with nCino. With their support, we are ready to bring even more ideas and innovation to the table. We’ll be expanding our reach across Europe, bringing new capabilities to regulated institutions of all sizes, and continuing to push the boundaries of what’s possible in client lifecycle management. The challenges are widespread, complex, and rapidly changing, and I am personally excited about continuing to find innovative ways to help our customers solve them.

Whether you’re a long-time FullCircl customer or new to our platform, rest assured that our commitment to your success remains stronger than ever. Together with nCino, we are ready to provide you with the tools, data, and insights you need to thrive in a rapidly changing regulatory environment.

Thank you for your continued trust and support. I am, and we are, excited to enter this next phase looking forward to the challenges and opportunities that lie ahead.

--

Andrew

CEO & Co-Founder, FullCircl

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