1 Obligations under the regulations
EU financial sanctions are directly effective. Once a person or entity is listed, you must not make funds or economic resources available to them, and you must freeze what you already hold. The Central Bank of Ireland administers financial sanctions for Irish financial institutions and is a competent authority for EU restrictive measures.
The Central Bank expects firms to monitor the Consolidated EU Sanctions List and the UN lists relating to terrorism and proliferation. On a confirmed match, freeze, do not deal, and report to the Central Bank using the Financial Sanctions Return Form. AML/CFT duties under Part 4 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 sit alongside sanctions — they are not a substitute for list screening.
The CBI’s work on the life sector is a useful benchmark for insurers: screen customers and beneficiaries, including before a claim is paid; document a risk-based frequency for ongoing screening; and have an escalation path for potential matches. Screening only at claims stage is not enough if you have already been providing cover or holding premium.
2 What do I need to do
Write down who you screen, against which lists, and when. Then run that policy every time — onboarding, payment, claim, and when the list changes.
1. Decide the screening population and the lists
Customers, beneficial owners, directors, counterparties, payees, and (for life and claims) beneficiaries. Screen against the Consolidated EU list and relevant UN lists. Decide whether you also screen UK or other lists if you have exposure there. Regzact can assist: run UK and EU sanctions searches in bulk from files or APIs.
2. Screen at take-on, on list change, and before value leaves the firm
New business, mid-term changes, claim payment and refunds are typical trigger points. Rescreen when the EU list is updated. Do not rely on a single check at onboarding that is never repeated. Regzact can assist: record each search against the customer or partner profile and alert owners when a review is due.
3. Triage alerts — true match, false positive, or needs investigation
Compare dates of birth, addresses, nationalities and aliases. Document why you discounted a hit. A true match means freeze, stop the payment, and report. Regzact can assist: use AI to filter false positives so analysts spend time on real matches.
4. Escalate, report, and tell the business not to deal
Confirmed hits go to the MLRO / sanctions officer, then to the Central Bank. Keep a hold on the policy or payment until you have authority to act. Regzact can assist: generate tasks, send alerts, and keep the case on an auditable register.
3 What records do I need to keep
If the Central Bank asks how you complied with a listing that appeared on a Tuesday, you need to show who you screened, when, and what you did with the alert.
- The screening policy: population, lists, frequency, fuzzy-matching rules
- Who was screened, against which list version, and on which date
- Alert decisions — true match, false positive, or still under review — with reasons
- Freeze actions, payment blocks, and any licence or authorisation relied on
- Reports submitted to the Central Bank (Financial Sanctions Return Form) and internal escalation
- Quality testing of the screening tool and samples of discounted alerts
- Training records for staff who discount alerts
4 Using AI to streamline the process
Fuzzy matching generates noise. That is expected — and it is where AI helps, provided a person still owns the true-match decision.
- Rank alerts so obvious false positives (wrong country, impossible date of birth) are cleared faster
- Explain, in a short note, why two names look similar but are probably different people
- Spot customers or payees who have never been screened, or not since a list update
- Draft the internal escalation note for a potential true match
Do not auto-close a possible true match. Use AI to weed out false positives; keep freeze-and-report decisions with the sanctions officer.
5 How Regzact can help
Regzact’s sanctions screening is built for insurance operations: bulk search, UK and EU lists, and an AI filter for false positives.
- Screen customers and counterparties from files or APIs
- AI-assisted triage so analysts are not clearing obvious non-matches by hand
- Evidence of each search on the customer or partner profile
- Tasks, alerts and management reporting on outstanding alerts and true matches
Staff fitness, partner profiles, error registers and data-request files sit on the same platform if a sanctions hit overlaps with another event. Regzact can assist with each step of this process.
This is a practical how-to for compliance managers. It is not legal advice. Always check the current text of the regulations and your own policies before you act.