Sanctions screening checks investors, beneficial owners and counterparties against government sanctions lists such as OFAC, the UN, the EU and the UK. A fund may not accept or continue to hold money for a sanctioned person and must freeze and report any match.
Screening runs at onboarding, before each dealing and continuously against list updates. A confirmed match leads to rejection of the subscription or, for an existing investor, a freeze on the holding, compulsory redemption where permitted, and a report to the relevant authority.
Alongside KYC and PEP screening, sanctions screening is the core of a fund's anti-money-laundering programme.
POD screens all investors and managers' principals against sanctions lists at onboarding and on an ongoing basis, and can compulsorily redeem an investor who becomes sanctioned.
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