What does a Sanctions Screening Committee do?

A Sanctions Screening Committee is a governance body responsible for the oversight of the sanctions compliance program. Its primary functions include reviewing and approving the program's framework, policies, and risk appetite. A key part of this oversight is managing and reviewing the effectiveness of the screening process through key performance indicators (KPIs) and metrics. This ensures the program is operating as intended and meeting regulatory expectations. The committee provides strategic direction rather than performing day-to-day operational tasks.

B. Unfreezing accounts is an operational decision executed by a specific team after investigation, not the primary role of an oversight committee.

C. Reporting is done to regulatory bodies or senior management, not vaguely defined "contractor agencies," which is an inaccurate term in this context.

D. This is too narrow; the committee oversees all sanctions screening metrics, not just those related to positive (adverse) media.

1. ACAMS. (2023). CAMS-RM Study Guide. Chapter 3: Governance and Leadership. The guide discusses the role of board and senior management committees in overseeing the risk management framework, which includes setting risk appetite and monitoring program effectiveness through metrics.

2. The Wolfsberg Group. (2019). Guidance on Sanctions Screening. Section 3.2: Governance and Oversight. This document emphasizes the need for "appropriate governance and oversight," which includes "management information (MI) and metrics to monitor the effectiveness of the screening programme."