A UK accountancy practice is a relevant person under the Money Laundering Regulations 2017 (as amended). The firm must identify and verify every client and every beneficial owner, assess the risk each relationship carries, and keep that assessment under review for as long as the relationship lasts. Where a client is a politically exposed person, or connected to one, enhanced due diligence applies.
Sanctions sit under a separate regime and catch a much wider net. Financial sanctions administered by OFSI apply to everyone in the UK, not only to regulated firms, and breaching them is a strict liability offence. A practice therefore has two distinct obligations that are often discussed as one: risk-based due diligence under the money laundering rules, and absolute compliance with sanctions law.
This guide sets out what screening actually involves, so a firm can judge what it needs from a screening provider and what it needs from the rest of its systems.
What the screening datasets cover
Screening tools query consolidated datasets built from primary sources. Understanding what sits inside them is what lets a compliance officer interpret a result rather than simply react to it. A hit grounded in a named source list is a very different thing from an unexplained risk score.
- The UK OFSI consolidated list of financial sanctions targets
- EU, OFAC and United Nations sanctions designations
- Politically exposed person registers across multiple jurisdictions
- Adverse media flags drawn from public reporting
- Linked entity relationships covering directors, shareholders and close family
What a hit actually means
A hit is not a finding. It is a question the firm now has to answer. Screening matches on attributes such as name similarity, date of birth and country, and common names generate false positives constantly.
The work is in the adjudication. Someone competent has to compare the matched entity against what the firm knows about the client, decide whether it is the same person, and record why. That decision, and the reasoning behind it, is the part a supervisor will ask to see.
Ongoing monitoring is the harder half
Screening once at onboarding is the easy part. The regulations require ongoing monitoring across the life of the relationship, and circumstances change after the file is opened.
A client may become a PEP because they were appointed to a public role. A beneficial owner may appear on a list that did not exist at onboarding. Manual monitoring almost always fails at scale, because nobody sets a calendar reminder for six hundred clients. Whatever tool a firm chooses, the question to ask is whether it re-screens on a schedule and surfaces only the changes since the last check.
A note on domestic PEPs
Treating every PEP as automatically high risk is a common and expensive mistake. UK guidance is explicit that a domestic PEP should be the starting point for a lower level of enhanced due diligence than a foreign one, absent other risk factors. Firms that apply a blanket approach create work for themselves and friction for clients who have done nothing wrong.
The audit trail is what gets inspected
Supervisors rarely ask whether a firm screens. They ask the firm to evidence it. That means showing, for a named client on a named date, what was checked, what came back, who reviewed it, what they decided and why.
Records under the money laundering rules must be kept for five years from the end of the business relationship. A screenshot pasted into a folder is not a durable answer, because it carries no reviewer, no rationale and no reliable date.
Where Accupe fits, and where it does not
Accupe does not perform sanctions, PEP or adverse media screening. If a firm needs screening, it needs a dedicated screening provider, and that decision should be made on the quality of the data and the adjudication workflow.
What Accupe does hold is the record around it. Identity verification through KYC Smart Capture, the client risk assessment, the engagement letter, the supporting documents, and an append-only audit trail of who did what and when. The screening decision and its rationale can be recorded against the same client record that holds everything else a supervisor will ask for, rather than living in a separate tool and a separate folder.
What to ask a screening provider
Firms comparing providers tend to focus on list coverage, which is rarely the differentiator, since most reputable vendors draw on the same primary sources. The questions that separate them are about the work that follows a match.
- How often is each underlying source refreshed, and is the dataset version recorded against each check?
- How is fuzzy matching tuned, and can the threshold be adjusted per risk band?
- Does the tool re-screen automatically, and does it surface only new hits since the last run?
- Can an adjudication decision and its rationale be exported for a supervisory visit?
- Is pricing per check, per seat or flat? Per-check pricing quietly encourages firms to screen less than they should.
What stays a firm responsibility
No tool discharges the duty. Submitting a Suspicious Activity Report to the NCA, deciding whether to end a client relationship, and the professional judgement of the MLRO all remain with the firm. Software can surface the risk and evidence the process; it cannot make the call.
Closing
Sanctions and PEP screening is not the part of a practice that wins new work. It is the part that ends careers when it fails. Getting it right means choosing a screening provider on the strength of its adjudication and monitoring, and making sure the resulting decisions land somewhere durable, next to the rest of the client file, rather than in an inbox.
