As promised: the one-page escalation memo template is up with this session's handouts. Fields: match details, list, score, disposition, reviewer, date, and, the part auditors love, the 'why this is/isn't our party' narrative in two sentences. Use it, adapt it, tell me what breaks.
20MaySanctions Screening for SMEs: Building a Defensible Process
You don't need enterprise software to screen properly. A right-sized process for small trade teams.
About this session
What this session covers
Hans Müller showed how a two-person compliance team can run a screening process that survives an audit: list selection, screening cadence, fuzzy-match thresholds, documenting false positives, and the escalation memo template he has used for two decades. Recording and template links in the thread.
Agenda
- Which lists actually matter for your trade lanes
- Screening cadence: order, party, payment
- False positives: document or drown
- The one-page escalation memo
Session materials
3 files · 1 not yours to open yetOne handout was released to the people who attended the live session.
The one-page escalation memo
Hans's template, the one referenced in the Q&A thread. Adapt the narrative field to your lanes.
escalation-memo-template.docx · 62 KB
Screening cadence worksheet
Order, party and payment stages mapped against who signs off each one.
screening-cadence.xlsx · 120 KB
Demo build. Files aren't served yet; the covers are real.
Session replay
Available to the 4 members who attendedQ&A, still open
The session ended; the conversation didn't. Follow-up questions welcome.
3 replies
Follow-up from the session: do you re-screen at payment stage as well as order stage? Our bank does their own screening and I'm wondering if ours is redundant.
Yes, screen at payment too, your bank screens for THEIR risk appetite, not your licence conditions. Their clean pass is not your defence file. It costs you seconds; the asymmetry decides it.
