Secondary Sanctions Screening - Davies

Secondary Sanctions Screening: Reducing False Positives and Strengthening Compliance

How financial institutions can improve sanctions risk detection while reducing alert volumes and operational strain

The Challenge with Traditional Sanctions Screening

As global sanctions regimes evolve and enforcement activity intensifies, financial institutions face increasing pressure to identify sanctions risk accurately and efficiently. Traditional sanctions screening, heavily reliant on name‑matching and static rules, is struggling to keep pace with growing transaction volumes and increasingly complex exposure.

The result is a high volume of alerts—90–95% of which are false positives—placing significant strain on compliance teams and operational budgets.

 

The Operational Impact of False Positives

Reviewing sanctions alerts is time‑consuming and resource‑intensive. With analysts typically spending between 5 and 20 minutes per alert, organisations can lose hundreds of hours each month investigating low‑risk matches. This reduces efficiency, increases costs and limits the time available to investigate genuine risk.

As regulatory scrutiny increases, improving alert quality without weakening controls has become a critical compliance objective.

 

What Is Secondary Sanctions Screening?

Secondary sanctions screening is applied after primary screening and before case generation. It enhances initial matches by enriching customer and transaction data with additional attributes such as dates of birth, addresses, government identifiers, PEP exposure, adverse media and behavioural indicators.

This additional context allows institutions to calculate more accurate match confidence scores and suppress alerts that present minimal sanctions risk.

 

Identifying Indirect and Secondary Sanctions Risk

Regulators are increasingly focused on indirect sanctions exposure, where organisations may facilitate business for sanctioned entities through intermediaries. Secondary screening supports this by moving beyond basic name‑matching to identify contextual, behavioural and relationship‑based risk.

 

Delivering Measurable Compliance Outcomes

When tailored to an organisation’s risk profile and supported by strong data governance, secondary sanctions screening can reduce alert volumes by 40–50%. This enables compliance teams to focus on material risk, improve decision‑making and maintain regulatory confidence in an increasingly volatile geopolitical environment.

Meet the expert

Ramu Chandra

Principal Consultant

Risk & Compliance

Ramu Chandra is a Principal Consultant and Head of Sanctions within Risk & Compliance at Davies. He brings close to three decades of experience across financial services, with deep specialism in OFAC and global sanctions compliance.