LFIs should document and track sanctions screening outputs in order to identify and address any technical or operational issues and understand key risks or trends over time. Irregularities in sanctions screening system performance, including significant changes in the volume of apparent matches to sanctions lists over time, may be indicative of underlying data quality or data integrity issues or of the need to recalibrate sanctions screening search logic. Identified data quality or integrity issues should be reported back to designated data owners, and apparent screening logic issues should be reported back to model owners for tuning and optimization.

In addition, LFIs should ensure that senior management is regularly updated on the performance and output of their sanctions screening program, including through the provision of metrics, trends, and other MIS reporting generated by sanctions screening systems or produced by sanctions screening alert review and investigation teams. Such reporting may include an analysis of the number and type of screening hits and the proportion of apparent matches that are cleared as false positives compared to those that are confirmed as potential or true matches. Sanctions screening-related reporting and analysis should feed back into an LFI’s financial crimes risk assessment, and LFI management should use this information to ensure that the institution’s customers and transaction remain within the LFI’s risk appetite and that activity exceeding its risk appetite is addressed through appropriate risk mitigation measures, up to and including account activity restrictions and customer exit.