Who It’s For
- Organisations with cross-border counterparties that need sanctions coverage mapped clearly (UN/EU/UK/OFAC and relevant local/sector rules)
- Teams that need repeatable list-update routines, tuned screening, and clear escalation notes
- Firms that must show diligence to banks, auditors, and counterparties with a clear, evidence-based audit trail
Compliance support for 700+ Cyprus entities. CySEC ASP License 135/196. Response within four business hours.
What You Get
- Regime mapping note (what applies, where, and why) and update schedule
- List update procedure with update proofs and a “catch-up” routine for missed updates
- Name-matching tuning sheet (thresholds, name variants, and non-Latin name rules)
- Ownership and control guidance (including the 50% rule) with an exceptions register
- Escalation and licensing workflow with decision templates and evidence standards
- Registers: alerts and outcomes, exceptions, and change log
- Archive structure and retention guidance aligned to your policy
- Simple management report template (volumes, true matches, ageing)
Process
- Scope & baseline: confirm regimes, jurisdictions, products, risk appetite, and current tools.
- Map obligations: turn regime requirements into practical steps (screening, ownership checks, monitoring).
- Configure & tune: set list sources, matching thresholds, name rules, user roles, and change control.
- Run daily screening: review alerts, save evidence, escalate possible true matches, and update registers.
- Review & improve: test the controls on a schedule, update the change log, and support audits/exams.
Coverage & Update Schedule
| Regime | Main Update Source | Typical Update Frequency | Trigger Examples | Output |
|---|---|---|---|---|
| UN | UN Security Council updates | Daily check / on change | New resolutions; list amendments | Update log + full re-check of clients/partners |
| EU | Official Journal / consolidated list | Daily check / on change | Package updates; guidance updates | Change note + screening run |
| UK | OFSI consolidated list | Daily check / on change | List additions; ownership guidance | Update proof + exceptions review |
| OFAC (US) | SDN/NS-PLC lists, FAQs | Daily check / on change | SDN additions; 50% rule guidance | Full re-check of past clients + short note |
| Local / Sectoral | National/sector authority sites | Weekly or per event | New sector bans; licensing notes | Impact note + control update |
We align manuals to your policy and counterparty expectations. This page is informational; it is not legal or regulatory advice.
Case Study
Sanctions Monitoring & Escalation Framework for an Overseas Organisation (Anonymised)
Client: Overseas trading/services organisation with cross-border counterparty exposure (anonymised)
The organisation needed a defensible sanctions control model: clear regime coverage, consistent list updates, tuned screening, and an escalation path that produced clean records for counterparties and banking reviews.
MegaServe mapped the applicable regimes (UN/EU/UK/OFAC plus relevant local/sector measures), implemented a list-update procedure with proofs and trigger-based full re-checks, and tuned name matching (including name variants and non-Latin name rules) to reduce noise without weakening controls.
We then defined a simple escalation workflow for possible true matches (case file → MLRO/counsel review → decision note), and set up registers and reports so decisions stayed clear, consistent, and easy to audit.
Result: the framework closed without observations in the next correspondent bank review, false-positive alert volume dropped by over 60% after name-matching tuning (without weakening coverage), and a subsequent OFAC list update triggered a same-day full portfolio re-check with a written impact note — demonstrating a defensible response under scrutiny.
Requirements (Inputs Checklist)
| Policy & Scope | Tools & Data | Governance & Records |
|---|---|---|
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Share sensitive materials via VDR only. We provide an index and permissions model at kickoff.
Controls & Quality
- Two-person control for list changes and true-match decisions
- Separate roles for tool configuration and case decisions
- Quality checks on decisions and regular effectiveness testing
- Assumptions and exceptions register with written reasons
- Role-based access, least privilege, and a full audit trail in the VDR
Risk & Consequences
- Criminal liability: sanctions breaches can result in criminal prosecution of individuals and the organisation — this is not just a regulatory fine risk.
- Asset freezing: dealing with a sanctioned person or entity can trigger asset freezes and reporting obligations that disrupt operations immediately.
- Bank derisking: banks terminate relationships with clients who cannot demonstrate adequate sanctions controls — this is often the first and most immediate consequence.
- Regime complexity: overlapping UN/EU/UK/OFAC requirements with different ownership rules and update schedules create gaps that only a systematic approach can close.
FAQs
Which regimes do you cover?
UN, EU, UK, OFAC (US), and any local or sector rules relevant to your footprint. This is documented in the mapping note with an update schedule.
Do you provide legal advice or licensing services?
No. We document and operate processes and evidence. Legal interpretation and licence/exemption requests are handled by your counsel and the authorities.
How quickly are list updates applied?
Same day for major regimes where tools allow automated updates. Where it is manual, we keep update proofs and an impact note on file.
Can you guarantee zero sanctions exposure?
No. We implement risk-based controls, checks, and documentation to reduce risk and show diligence, but we cannot eliminate risk.
How do you handle the "50% rule" and complex ownership?
We apply aggregation and control tests per your policy, record the reasoning, and escalate difficult cases with supporting evidence for MLRO or counsel review.
What is a sanctions compliance programme?
It is a documented framework that defines which sanctions regimes apply to your business, how you screen clients and counterparties against those lists, how list updates are tracked and applied, how alerts are triaged and escalated, and how decisions are recorded for audit. We build and operate this framework so your team has clear steps to follow and your records are defensible under scrutiny.
How do you price sanctions compliance work?
We offer fixed-fee packages for a full sanctions programme build (regime mapping, list-update SOP, 50% rule guidance, escalation workflow, training pack, and registers) with scope agreed in writing. Ongoing operations (daily screening, list-update checks, alert triage, and periodic testing) can be scoped as retainers or per-alert fees. Remediation following a bank review or regulator finding is priced based on the gap analysis. We provide a clear written quote after scoping with no hidden charges.
See also
Client Screening Services · Know Your Client (KYC) Procedures · AML Procedures & Manuals
Other Jurisdictions (on request)
Where required, we coordinate sanctions-compliance documentation through vetted associates in selected jurisdictions.