An effective sanctions compliance program requires that screening be conducted against the most current version of all relevant sanctions lists. Sanctions lists are frequently updated by authorities (e.g., OFAC, UN, EU). Any delay in updating the institution's internal lists and executing the screening process creates a compliance gap, potentially resulting in a violation. Therefore, prompt updates and screening upon list availability are critical operational requirements.

A. Senior management approves the sanctions policy but does not create or issue the sanctions lists; these are provided by governmental and international bodies.

B. A registration or approval regime applies to the institution itself (e.g., an MSB), not to the operational process of sanctions screening.

D. While dispute resolution is part of a compliance program, it is not the primary factor for ensuring the prompt execution of the screening process itself.

1. ACAMS CAMS Risk Management Study Guide (2020), Chapter 3: "Sanctions Screening," emphasizes the critical importance of timely updates to sanctions lists, stating that "the lists used for screening must be current" and that processes must be in place to ensure new lists are implemented promptly.

2. Financial Action Task Force (FATF). (2019). Guidance on Proliferation Financing Risk Assessment and Mitigation. Section 67. This guidance highlights the need for "ongoing monitoring" which includes processes to screen against updated lists of designated persons and entities.