Screening customers at onboarding and quarterly thereafter is not sufficient to ensure compliance

with economic sanctions, as sanctions lists may change frequently and the financial institution may

not be aware of the latest updates. Screening should occur promptly after list updates to ensure that

the financial institution is not dealing with a sanctioned individual or entity, or facilitating a

prohibited transaction. This is recommended by the international guidance from the Financial Action

Task Force (FATF) and the Wolfsberg Group12. Screening and performing enhanced due diligence on

new relationships is also important, but not the only step to ensure compliance.

CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: Sanctions, page 86

The Wolfsberg Group Correspondent Banking Due Diligence Questionnaire 2014, Section 5: Sanctions

Policy, page 12

ACAMS CAMS Certification Video Training Course - Exam-Labs, Video 3.1: Sanctions

Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition),