What should be the frequency of sanctions screening for a customer once they have been onboarded by a financial institution?

Daily screening represents an excessive frequency for most financial institutions, as it can lead to unnecessary operational strain and resource allocation. While it aims to detect immediate changes in sanctions lists, it often results in a disproportionate response to risks that are typically assessed during periodic reviews.

Weekly screening still imposes a frequent burden that may not align with the actual risk exposure of many customers. This frequency might lead to inefficiency and increased workload without providing substantial additional security, given that most sanctions lists are updated less frequently than once a week.

While this approach may seem reasonable, it overlooks the necessity of consistent monitoring in the dynamic regulatory environment. Changes in sanctions can occur independently of a customer's risk profile, making it essential to have set screening intervals that are not solely reliant on risk assessments.