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Sanctions screening beyond account opening: Why ongoing monitoring matters

Terri Luttrell, CAMS-Audit, CFCS
July 8, 2026
0 min read

Why ongoing sanctions monitoring matters

Most financial institutions understand the importance of screening new customers against sanctions lists during onboarding. It is a foundational part of a strong compliance program and an important step in preventing prohibited relationships.

But what happens after the account is opened? That question deserves more attention. While sanctions screening often begins during onboarding, it should not end there. Customers change, sanctions lists change, and risk changes. Institutions that rely solely on one-time screening may not discover an issue until it has already created operational challenges, required extensive investigation, or raised concerns during an examination.

An effective sanctions screening program recognizes that compliance is an ongoing process, not a single event.

This article covers these key topics: 

Evolving risks

A customer who presents little risk today may look very different a year from now. A business customer may add new beneficial owners. An existing customer may begin sending international wires for the first time. A company may expand into new markets or establish relationships with foreign entities. At the same time, the Office of Foreign Assets Control (OFAC) continues to update sanctions lists in response to geopolitical developments.

None of these developments are unusual. They are part of doing business. The challenge is ensuring your sanctions screening program can identify changes that may require additional review.

That does not mean every customer should be screened every day. It does mean institutions should have a well-documented risk-based strategy for determining when additional screening makes sense and be prepared to explain that strategy to examiners.

 

Four events that should prompt a second look

Every institution’s risk profile is different, but there are several situations in which additional sanctions screening warrants consideration.

Updates to sanctions lists. New sanctions designations can affect existing customer relationships. Institutions should consider how updates to sanctions lists are incorporated into their screening processes and whether existing customers are reviewed when appropriate.

Changes in beneficial ownership. Ownership changes can introduce new risks, particularly for commercial customers. Rescreening beneficial owners helps ensure institutions have an accurate understanding of who they are doing business with.

Significant changes in customer information. Changes to legal names, business structures, addresses, or other identifying information may warrant additional screening depending on the institution’s risk profile.

New or higher risk activity. A customer who begins conducting international transactions or engaging in higher-risk business activity may require additional review, even if the original onboarding presented no concerns.

These events do not automatically indicate suspicious activity. They provide opportunities to reassess risk using current information.

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The cost of reactive screening

When institutions discover potential sanctions issues months or years after onboarding, the investigation is rarely simple.

Compliance teams must review customer records, analyze transaction activity, gather supporting documentation, and determine whether the alert represents a true match or a false positive. Operations teams may delay transactions while the review is completed. Relationship managers answer customer questions about unexpected delays.

Even when the alert is ultimately cleared, the institution has already invested valuable time and resources. Reactive screening often creates work that could have been reduced or avoided through earlier identification of changing risks.

False positives

False positives are an unavoidable part of sanctions screening, but excessive false positives can become an operational risk in their own right.

When investigators spend a large portion of their day clearing low-value alerts, they have less time to focus on higher-risk activities. Alert fatigue can also make it more difficult to identify truly significant matches.

That is why institutions should periodically evaluate not only the number of alerts they receive, but also the quality of those alerts.

Questions worth asking include:

  • Are investigators spending too much time reviewing obvious false positives?
  • Have customer demographics or business lines changed in ways that affect screening performance?
  • Is the institution regularly reviewing screening thresholds and matching logic?
  • Does the current process support efficient investigations while maintaining appropriate risk controls?
  • If sanction screening software is in use, how can the settings be modified to reduce false positives?

Reducing unnecessary alerts is not about lowering compliance standards. It is about helping compliance professionals spend their time where it provides the greatest value.

 

Compliance reducing friction

Strong sanctions screening protects the institution, but it should also support efficient operations. When screening processes are well designed, compliance teams spend less time resolving preventable issues. Customers experience fewer unnecessary delays. Business lines have greater confidence in the consistency and documentation of reviews.

That is why proactive sanctions screening is more than a regulatory expectation. It is a practical way to improve operational efficiency while maintaining effective risk management.

 

Building a stronger sanctions program

Sanctions compliance is becoming more complex as customer relationships, payment activity, and global events continue to evolve. Financial institutions that view sanctions screening as a one-time onboarding requirement may struggle to keep pace with those changes.

Instead, institutions should periodically evaluate whether their screening strategy reflects how risk develops over the life of a customer relationship. Efficient sanctions screening software can support that effort by helping institutions automate ongoing screening, reduce unnecessary false positives, and give compliance teams more time to focus on higher-risk activity. Many sanctions screening solutions also allow institutions to add supplemental watchlists, giving them the flexibility to align screening with their specific risk profile rather than limiting reviews to only what is required.

The most effective sanctions programs do more than identify potential matches. They establish thoughtful processes for determining when additional screening is appropriate, reduce unnecessary investigative work, and help compliance teams focus on the risks that matter most.

That approach strengthens compliance, supports operational efficiency, and ultimately helps build confidence among regulators, employees, and customers alike.

 

Find out how to automate sanctions screening to reduce false positives.

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About the Author

Terri Luttrell, CAMS-Audit, CFCS

Compliance and Engagement Director
Abrigo
Terri Luttrell is a seasoned AML professional and former director and AML/OFAC officer with over 20 years in the banking industry, working both in medium and large community and commercial banks ranging from $2 billion to $330 billion in asset size.

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About Abrigo

Abrigo enables U.S. financial institutions to support their communities through technology that fights financial crime, grows loans and deposits, and optimizes risk. Abrigo's platform centralizes the institution's data, creates a digital user experience, ensures compliance, and delivers efficiency for scale and profitable growth.

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