ONGOING sanctions



The AML Suite’s Ongoing Sanction Monitoring is performed automatically on a daily basis, screening the entire client database against the latest version of updated Sanction lists. According to the regulators’ mandatory requirements, each Financial Institution must screen its client database to verify against any changes and updates. Fincom’s AML SUITE automatically uploads the Sanction lists and other Internal lists, updating any changes of the corresponding entries, as well as additions to and removals from the lists. One the entries are updated, the ONGOING SANCTION MONITORING automatically screens the updated customer base against the updates. This service is performed at nighttime, without interrupting daily operations.


The Automatic Ongoing Monitoring can also be applied to Internal Lists for a regular timely checks and updates. In addition to regulators’ mandatory requirements for Ongoing Sanction Monitoring, each Financial Institution may have its own internal blacklists, restriction lists, or similar, that are updated regularly. Fincom’s AML SUITE automation for Ongoing Monitoring uses both the Persistence mechanism and the automatic Lists Synchronization to support monitoring of all type of lists, making sure to stop any unauthorized transactions.


Fincom’s Persistence Mechanism provides smart automation for past approvals management, using trend analysis by constant monitoring of historical data vs. current data, based on a scheduled or ad-hoc triggered event. The mechanism automatically alerts on updates in either Sanction lists or other lists, e.g.: internal blacklists, thus replacing the risky practice of whitelisting by smart mechanism for past approvals monitoring. The Persistence Mechanism ensures the prevention of potential penalties, while keeping high efficiency and supporting cost reduction in compliance operations.

Fincom AML Suite’s Persistence Mechanism:

  • Smart automatic alert suppression for all past approvals
  • Replaces the risky practice of whitelisting
  • Saves data “snapshot” at the moment of decision
  • Alerts in case of changes in Sanction lists or other databases


The complex task of screening the customer roster results in many False Positives that re-appear and require manual resolution, causing back-logs  and heavy workload that need to be processed. In trying to tackle this issue FI’s have incorporated the practice of “White-Listing:” Once a Name/Entity is cleared as “verified,” it is “white-listed” and is no longer screened against updated data, automatically bypassing future ongoing screening processes, including transactions.

Whitelisted customers can in time become sanctioned, simply due to new additional information that identifies them as sanctioned persons. The whitelisting practice inevitably leads to fines and penalties (example: see the case of ING bank, that had numerous whitelisted sanctioned ISIS terrorists, resulting in a 750 million Euro fine).

Fincom’s Ongoing Monitoring Automation eliminates the need of whitelisting and helps preventing risks and penalties.

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