Front door
KYC & onboarding
The onboarding due diligence that screening runs inside, before the relationship opens.
KYC & onboardingSanctions
screening
A designated party must never get through the front door, and a client who was clean at onboarding can be listed tomorrow. Sanctions screening checks clients, owners and counterparties against the SECO, EU, UN and OFAC lists at onboarding and on a periodic re-scan. Most hits are false positives, so the value is in the clearance: confirming a match, documenting the decision, and escalating a true one. We set the lists to your real exposure and build the path that holds up at audit.
At a glance
Catch real designations, clear the noise.
Lists set to your exposure; clearance built to audit.
- Lists
- SECO, EU, UN, OFAC
- When
- Onboarding & periodic re-scan
- Checks
- Clients, owners, counterparties
- Most hits
- False positives to clear
- True match
- Freeze / decline / report
The essentials
What sanctions screening is
Sanctions screening checks clients, beneficial owners and counterparties against the lists of designated persons and entities, so the firm does not deal with a sanctioned party. Swiss firms screen against the SECO sanctions, issued under the Embargo Act (EmbG), and typically the EU, UN and OFAC lists too. This is a separate legal regime from the Anti-Money Laundering Act, though both controls sit in the same framework. It runs at onboarding and on a periodic re-scan, because lists change constantly. A hit triggers a clearance process, not an automatic exit. That process, documented, is what the audit tests.
Who this is for
- financial intermediaries building screening into onboarding;
- firms with international clients, owners or payment chains;
- firms drowning in false positives or missing list coverage;
- firms whose hit-clearance is undocumented or inconsistent.
Where it fits
Screening is part of onboarding, complements transaction monitoring, and sits in the policy framework.
The lists
Lists and when to screen
The right list set follows the firm’s footprint, and screening runs at the points where a designation matters.
| List / point | Why it matters |
|---|---|
| SECO (Swiss + UN) | The baseline Swiss obligation |
| EU consolidated | Clients and payment chains touch the EU |
| OFAC (US) | USD exposure carries OFAC risk |
| Onboarding + re-scan | Catch at entry and as lists change |
Too few lists and the firm misses designations it is exposed to; too many irrelevant ones and the clearance team drowns in noise. The list set is a calibration to real exposure (whom the firm serves, in what currencies, through which banks), not a generic default. We set it to the firm.
The flow
How screening runs
Automated matching feeds a disciplined human clearance with a defined escalation path. Every hit leaves a record.
- Step 1
Screen at onboarding
Checking the client, owners and counterparties against the list set before the relationship opens.
- Step 2
Clear or confirm
Comparing identifying details to confirm whether a hit is a real match or a false positive.
- Step 3
Act on a true match
Freezing, declining or reporting as the sanctions regime requires, on the defined escalation path.
- Step 4
Document the decision
Recording the reasoning for every hit, true or false, so the control is demonstrable at audit.
- Periodic
Re-scan the book
Re-screening the existing client base as lists change, so a newly designated client is caught.
Budget
What it costs
Cost depends on the firm’s size and the volume of clients and counterparties to screen, the breadth of list coverage, and whether the firm wants the clearance run for it or supported. A small book with a tuned list set carries far less clearance load than a large international one.
We scope and quote against the firm’s profile. Pricing is on request.
Discuss your screening What it takes
What good screening requires
Screening that catches designations and survives audit rests on:
- list coverage calibrated to the firm’s real exposure;
- screening at onboarding and on a periodic re-scan;
- a clearance process that confirms hits reliably;
- a defined escalation path for a true match;
- a documented decision for every hit, true or false.
A hit is the start of a process, not a verdict
The instinct on a sanctions hit is either to panic and exit or to wave it through as “probably a false positive”. Both are wrong. Most hits are genuinely false positives, but the firm cannot assume it; it has to confirm, by comparing identifying details, and document why. And the minority that are real matches demand a decisive, regime-compliant response. The control is the disciplined process between the alert and the action: reliable clearance of the noise, decisive handling of the real, and a record either way. That discipline is what we build and run.
Why Goldblum
Screening, in practice
Catching real designations while clearing the noise, and documenting both, is a discipline, not a switch. Setting it up and running it is the work this firm does.
Calibrated
Lists set to your exposure
SECO, EU, UN and OFAC coverage matched to whom the firm serves and in what currencies, not a generic default that misses or floods.
Disciplined
Clearance that holds up
A defined path from hit to decision (confirm, act, document) so false positives clear cleanly and true matches are handled decisively.
Demonstrable
A record for every hit
Documented reasoning on each alert, true or false, so the firm can show the SRO a complete, defensible screening trail.
Related
Around screening
Behaviour
Transaction monitoring
The complementary control that watches activity, where screening checks identity against lists.
Transaction monitoringRun it for me
External AML officer
The officer who runs the screening and the clearance day to day, under one mandate.
External AML officer FAQ
Sanctions screening: FAQ
01What is sanctions screening?
Sanctions screening is checking clients, beneficial owners and counterparties against the lists of persons and entities subject to financial sanctions, to make sure the firm does not deal with a designated party. It runs at onboarding, before the relationship begins, and again on a periodic re-scan of the existing book, because lists change constantly. A hit is not a verdict. It triggers a defined process to confirm whether the match is real and decide what to do. Screening is distinct from anti-money-laundering monitoring, though they sit in the same framework: monitoring watches behaviour, screening checks identity against lists.
02Which lists does a Swiss firm screen against?
At a minimum the Swiss sanctions administered by SECO under the Embargo Act (EmbG), which implement Switzerland's own measures and UN Security Council designations. Most firms also screen against the EU consolidated list and the US OFAC lists, because clients, counterparties and payment chains routinely touch those jurisdictions and exposure to them carries real risk regardless of Swiss law. The right list set depends on the firm's footprint: whom it serves, in what currencies, through which banks. We set the list coverage to the firm's actual exposure, not a generic default, so nothing material is missed and the firm is not drowning in irrelevant lists.
03When does screening happen?
At two points at least. First at onboarding, before the relationship is opened, as part of the due diligence, where a designated party should never get through the front door. Second on a periodic re-scan of the existing client base, because sanctions lists are updated frequently and a client who was clean at onboarding can be designated later. Some firms also screen on relevant events, such as a change in beneficial ownership or a new counterparty. The onboarding check plus the periodic re-scan is the baseline; the cadence of the re-scan is set to the firm's risk.
04What happens when there is a hit?
A hit starts a clearance process, not an automatic exit. Most hits are false positives (common names, partial matches, outdated data), so the first step is to confirm whether the match is genuine by comparing identifying details. If it is a false positive, it is documented and cleared. If it is a true match, the firm must act: freeze or decline as the sanctions regime requires, and report where reporting is mandated. The defined escalation path, who reviews, who decides, what is documented, is the part that matters, because an undocumented or inconsistent response to a hit is itself a finding. We build that path.
05Why are most hits false positives?
Because screening matches names, and names are not unique. A common surname, a transliterated name, a partial match or stale list data routinely produces an alert against someone who is not the designated person. A screening system with no false positives is usually one set too loose to catch real matches. The skill is in the clearance process: confirming quickly and reliably whether a hit is the real party, documenting the decision, and clearing the false positives without letting a true match slip through. We tune the screening and run the clearance so the firm neither misses designations nor chokes on noise.
06How does sanctions screening differ from transaction monitoring?
They answer different questions. Sanctions screening asks: is this person or entity on a list we must not deal with? It checks identity against designations, at onboarding and on re-scan. Transaction monitoring asks: does this client's behaviour fit their profile, or is something unusual? It watches activity over time. A client can pass screening and still trigger monitoring, or vice versa. Both sit in the AML framework and both feed the same escalation and reporting machinery, but they are separate controls. We build and run them as complementary parts of one system.
07Does the firm have to document false positives too?
Yes. Clearing a false positive without recording why is a gap. The auditor tests not just whether the firm screens but whether it handles hits consistently and can show its reasoning. A documented clearance (these identifying details differ, therefore not a match, reviewed by this person on this date) is what demonstrates the control works. An undocumented clearance looks the same as no screening at all. We make the clearance process produce a record for every hit, true or false, so the firm can show the SRO a complete, defensible trail.
08Can screening be automated?
The matching is automated. Software checks names against lists far faster and more completely than manual review, and at any real volume it has to be. But the clearance of hits requires judgement: deciding whether a match is genuine, and what to do about a true one, is not something to leave to a tool. The right setup is automated matching feeding a disciplined human clearance process with a clear escalation path. We set up the screening, calibrate it to the firm's exposure, and run or support the clearance, so the firm gets the speed of automation and the judgement a real match demands.
09What is adverse media screening, and is it part of this?
Adverse media (or negative-news) screening checks whether a client or counterparty appears in credible reporting linked to financial crime, corruption or other risk, beyond the formal sanctions lists. It is distinct from sanctions screening but complementary: a party may not be designated yet still carry real risk that public reporting reveals, which feeds the firm's risk classification and due diligence. For higher-risk relationships it is increasingly expected as part of a sound onboarding process. We can build adverse-media checks into the screening setup where the firm's risk warrants it, calibrated so they add signal rather than noise, and connected to the same clearance and documentation discipline as the sanctions checks.
10Can Goldblum set up and run screening?
Yes. We set the list coverage to the firm's actual exposure across SECO, EU, UN and OFAC, build the onboarding and periodic re-scan into the AML framework, and define the escalation path for hits: who reviews, who decides, what is documented. Where the firm wants it operated, our external AML officer mandate runs the screening and the clearance day to day. The aim is a control that catches real designations, clears false positives cleanly, and leaves the documented trail the SRO audit expects.
The client's stories
What clients say
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“Perfekter Service! Wir wollten eine AG in der Schweiz übernehmen und hatten kaum Zeit – innerhalb weniger Tage war alles organisiert, inklusive Notar, Handelsregister und Bank.”
“We consulted Goldblum and Partners for structuring our crypto project under Swiss law. Their team was clear about the threshold between non-custodial and financial-intermediary status.”
“Équipe sérieuse. La documentation AML fournie était claire et adaptée à notre activité crypto. Je recommande.”
“Professionisti veri. Conoscono bene la legge svizzera e si sono occupati di ogni aspetto del passaggio azionario.”
Is your screening catching the right names?
Tell us your client footprint and currencies. A partner sets sanctions screening to your real exposure (SECO, EU, UN, OFAC) with a clearance path that holds up at audit.
