Given the ongoing political unrest in the Middle East and the speed at which individuals, entities and entire regimes can be added to HM Treasury and OFAC’s consolidated sanctions lists (most recently, Libya and Tunisia), firms must ensure that their financial sanctions policies and procedures are effective and that in particular, systems for routine, real-time screening of all new and existing clients are in place. Screening should have adequate “fuzzy-matching” capabilities (to identify close matches – i.e. mis-spellings, alternative translations and other name variations) and where possible, should also scan shareholders, directors and other known beneficiaries of clients.

Certainly the recent sentencing in the SFO’s first conviction for breaching sanctions in Iraq and the FSA’s warning (referred to in Richard Burger’s recent post) should focus minds.