Sort: Sanctions Risk Factors by Where They Enter
Classify sanctions risk factors by the business touchpoint where controls should detect them.
Sort each risk factor by the touchpoint where the first practical control should sit. Customer or owner Product or service Geography or route Transaction or payment Intermediary or third party Beneficial owner uses a name variant that appears on a sanctions list Customer refuses to provide director or ownership information for review Product could be diverted for restricted end use after resale Service includes remote access for users in embargoed regions Shipment route passes through a high-risk transshipment corridor Billing address and delivery country conflict in a restricted-region pattern Payment instructions add an unfamiliar beneficiary bank before release Refund recipient…
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