A compliance officer needs to make a decision regarding an organization's sanctions screening process.

Sanctions and Compliance Domains state that screening must be applied to all relevant business activities and relationships that can expose an organization to sanctions risk. This includes customers, vendors, intermediaries, distributors, beneficial owners, and any party involved in transactions, supply chains, or service delivery.

Limiting screening only to customers is inconsistent with sanctions compliance expectations. Excluding vendors, intermediaries, or beneficial owners can expose an organization to significant sanctions violations due to indirect dealings with sanctioned parties. Comprehensive coverage of all business activities is the standard approach in an effective sanctions compliance program.

References from Sanctions and Compliance Domains:

Requirements for comprehensive sanctions screening across all relevant business relationships.

Inclusion of customers, intermediaries, vendors, distributors, and beneficial owners.

Risk-based approach requiring full coverage of business activities to prevent indirect sanctions exposure.