Beyond Names: What Else Needs Screening in a Payment Message?
Focusing only on the sender and recipient names is insufficient. Additional fields require screening for effective compliance. Banks learned this lesson through enforcement cases – for example, a financial institution was fined after it failed to screen the address field in transactions where customers explicitly mentioned “Iran” or “Cuba,” leading to sanctions breaches. Screening free text fields is also critical. To avoid such gaps, banks screen a range of data fields, including:
- Originator (Ordering Customer) or Debtor Name: The name of the sender of the funds.
- Beneficiary or Creditor Name: The name of the recipient of the funds. Both the final beneficiary and any intermediary beneficiary (e.g. in nested payment messages) are in scope.
- Beneficiary Bank and Originating Bank: The financial institutions involved (identified by name or BIC in message fields).
- Addresses and Location Fields: Payment messages often include address information for the originator or beneficiary. These free-text address fields should be screened for any sanctioned country or city, as well as for any sanctioned party names that might appear.
- Free-Text Fields: such fields as Payment Details/Reference or other free-text fields sometimes contain information that mention sanctioned entities, Countries, shipping routes, or goods subject to embargo (such as “Payment for [Goods] to [Company] in [Country]”).
- Other Parties (Intermediaries, Third Parties): In some cases, payment messages may include related parties like an intermediary bank, paying agent, or ultimate beneficiary owner. All parties involved in a transaction should be screened, including any intermediaries or owners referenced.
- Account Numbers and Identifiers: Generally, numeric account numbers alone are not directly screened against sanctions lists, as lists usually contain names and entities (with a few exceptions). However, certain identifiers like an IBAN can encode a country (first two letters) – if that country is sanctioned (e.g. Syria SY, Iran IR), it might inform the screening. In advanced systems, when additional data like passport numbers or national IDs are present (e.g. in message attachments or trade finance docs), those can also be screened against lists of blocked passports or IDs.
- Vessels and Aircraft
Some payments, particularly in trade finance, shipping, or aviation-related transactions, reference vessel names, IMO (International Maritime Organization) numbers, aircraft registration numbers, or call signs. These must be screened against specialized sanctions and export control lists (e.g., OFAC’s SDN List or BIS’s Entity List) that include blocked or restricted vessels and aircraft associated with sanctioned countries or operators.
Conclusion:
Comprehensive payment screening requires a multi-dimensional approach. Screening only names is no longer sufficient—regulators expect financial institutions to identify and block risks hidden in free-text, location, and reference fields, as well as in vessel and aircraft data. Leveraging advanced screening technologies ensures no critical detail goes undetected.
Fincom’s Payment Screening system ensures accurate, comprehensive compliance by thoroughly screening all relevant data fields, including structured and unstructured (free-text) data. As enforcement actions have shown, focusing solely on sender and recipient names is no longer sufficient; fields such as addresses, free-text notes, intermediary parties, and even embedded identifiers can expose institutions to serious regulatory breaches if left unchecked. Fincom’s robust, multi-field screening capabilities help financial institutions mitigate these risks by capturing hidden threats across the entire payment message — ensuring that no sanctioned entity, country, or transaction detail slips through the cracks.
