A name, country, vessel, bank, goods description or other data triggers a screening/risk alert.
What Happens During a Sanctions / Compliance Hold
A non-legalistic view of the operational steps when screening raises a question.
Operations may stop release while compliance determines whether the alert is a false positive or real restriction.
Bank may ask for ownership, identity, invoice, contract, vessel, goods, licence/end-user or source-of-funds information.
Compliance/legal/sanctions specialists review the facts and applicable restrictions.
Transaction may be released, rejected, blocked/frozen where law requires, or returned/closed depending on circumstances.
Bank records the decision and may update customer risk, screening data or future transaction requirements.
What can change from bank to bank?
The commercial objective may be similar while the bank’s internal route differs. Credit approval, collateral, compliance review, legal wording, message choice, fees and cut-off times can all vary. Always distinguish those bank-specific steps from the incorporated rules and the purpose of the SWIFT message.
