Customer Screening and Risk Control




Service Overview


OFAC regulations prohibit the provision of goods and services to blocked parties and nationals of certain blocked countries, and prohibit the operation of accounts for other comprehensively sanctioned countries. As a result, it is important to screen your customer base frequently to ensure that your company does not hold a prohibited account. Likewise, OFAC prohibits the operation of accounts that are 50% or greater owned by blocked parties, meaning that your company must be aware of the true beneficiary of the account at all times.

One of the great challenges to maintaining an effective and proactive compliance program is the lack of guidance and sometimes unpredictable direction of regulatory policies and decision making over time. When it comes to OFAC, the strict liability policy for stopping sanctioned transactions, even if the sanctioned party is working under a false name or shell company (“Shadow SDNs”), presents a major ongoing concern. To combat these risks, a good customer screening program needs to not only ensure that customer databases are screened regularly, but also follow KYC best practices that fully identify and screen for beneficial owners.

Blackstone offers a variety of tools and services to assist you in locating your riskiest customers and business lines and minimizing exposure to risky industries. Likewise, our experience in watch-list management will help your institution stay on-top of so called “Shadow SDNs,” companies that are owned by other SDNs.

Just as important to accounting for customer risks is the system used to control those risks. Blackstone will help you draft and maintain a thorough customer screening program and accompanying procedures and certify your program from top to bottom. We’ll work with you to test your existing screening tools, analyze any gaps in sanctions coverage, remediate errors or inconsistencies, and provide you with reliable tools and suggestions for bolstering your resources. This will maximize your screening capabilities and coverage, and mitigating your risk presented by customer accounts.


Key Features:

23 by 18 checkmarkDevelopment and implementation of robust policies and procedures

23 by 18 checkmarkSelection and/or tuning of an appropriate filter and both regulatory and custom watch-lists

23 by 18 checkmarkImplementing best “Know Your Customer” practices to identify ultimate beneficial owners and ensure quality of static data

23 by 18 checkmarkReview systems architecture to ensure all customer databases are screened