Which fields of a payment message are commonly subject to sanctions screening? (Select Three.)

Effective sanctions screening of payment messages requires a comprehensive analysis of all data fields that could identify a sanctioned party, location, or activity. The primary parties to the transaction, the remitter and beneficiary (A), are the most critical fields to screen. Additionally, all other entities involved in the payment chain, such as agents, intermediaries, and financial institutions (B), must be screened to prevent facilitation. Finally, free text fields (E) are crucial as they can contain unstructured data, such as the names of sanctioned vessels, cities, or alternative party names, which would not be captured by screening only the structured party fields.

C. Currency and notional value of the transaction: These fields are not screened against sanctions lists, which contain names of individuals, entities, and locations, not transactional values or currency types.
D. Effective day of the payment: The date of a transaction is a data point for record-keeping and timing, not an identifier that is matched against a sanctions list.
F. Sender's internal payment reference number: This is an internal tracking number for the originating institution and does not contain information about external parties or activities relevant to sanctions compliance. ---

1. ACAMS Certified Global Sanctions Specialist (CGSS) Study Guide, 2nd Edition.

Chapter 3: Sanctions Screening, Section: "What to Screen," pp. 68-70. This section explicitly states that screening must cover all parties to a transaction, including the originator, beneficiary, and any intermediary financial institutions. It also emphasizes the critical importance of screening unstructured data within free-text fields to identify hidden sanctions risks, such as references to sanctioned ports, vessels, or goods.

2. The Wolfsberg Group, "Payment Transparency Standards," October 2017.

Section: "Principles," p. 2. The document outlines that Payment Message Standards require the inclusion of the originator and beneficiary. It further states, "Each FI in the payment chain... should be able to apply its sanctions screening and other AML/CFT controls to the payment messages that it receives." This confirms the need to screen all parties (A, B) in the payment chain.

3. Financial Action Task Force (FATF), "International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation," The FATF Recommendations, October 2021.

Recommendation 16: Wire Transfers, Interpretive Note, p. 79. This recommendation mandates that originator and beneficiary information accompany wire transfers. It states, "Countries should ensure that financial institutions... monitor wire transfers for the purpose of detecting those which lack required originator and/or beneficiary information and take appropriate measures." This underpins the fundamental requirement to screen remitter and beneficiary data (A).