UNICORN PRIVATE Screening at onboarding or ongoing screening?
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In short
- Screening at onboarding checks a counterparty once, on the day the relationship starts; ongoing screening checks it again every time the lists change.
- Authorities in the United States, the European Union and the United Kingdom add and remove names throughout the year, often several times a month.
- A customer who was clean at onboarding can be listed later, so both checks are needed.
Most companies check a new customer or supplier before signing. Far fewer check the same counterparty again a year later. Yet a sanctions check is only valid on the day it is run: the lists move, and the relationship continues.
This guide compares the two approaches, explains why lists change so often and shows how to organise ongoing screening without overloading your team.
What onboarding screening does well
A check before the first contract has real value. It stops you from starting a relationship with a party that is already listed, it is easy to fit into the approval process and it creates a first record of due diligence. It is also the right moment to collect the data that makes later checks reliable: legal name, registration number, owners and directors.
Onboarding is also when the counterparty is most willing to share information. Once the contract is signed, asking for ownership documents or registration details becomes harder. Collecting them at the start, and storing them in the CRM next to the company record, makes every later check faster and more reliable, because each new alert can be compared with data you already hold.
Why it is not enough
Sanctions lists are living documents. The US Treasury publishes changes to its lists through recent actions, the European Union amends its regulations in the Official Journal, and the United Kingdom updates the UK Sanctions List. New designations can arrive on any working day, and in periods of international tension packages of hundreds of names are added at once.
There are other changes too. Companies change owners, and a new owner may be listed. Names are corrected or aliases added to existing entries. Each of these changes can turn a clean counterparty into a restricted one without anything happening in your relationship.
Banks know this, which is why they screen every payment and not only every new client. When your bank stops a transfer because the beneficiary was listed last month, the question it asks next is simple: when did you last check this customer? A recent, recorded check is the strongest answer you can give.
What ongoing screening means
Ongoing screening means checking your existing customers and suppliers against the current lists at regular intervals, and in any case whenever the lists change. In practice there are two ways to organise it:
- Periodic re-screening: the full portfolio is checked again at fixed intervals, for example every month or every quarter.
- Event-driven screening: every list update triggers a new comparison of the whole portfolio, so a new designation is found the same day.
The longer the interval, the longer a new designation can go unnoticed. Payments, deliveries and contracts made in the meantime can all count as dealings with a listed party.
Comparing the two approaches
| Question | Onboarding only | Onboarding and ongoing |
|---|---|---|
| Stops new relationships with listed parties | Yes | Yes |
| Finds customers listed after signing | No | Yes |
| Finds changes of ownership | Only if reported | Yes, if owners are monitored |
| Shows a continuous process to banks and auditors | Partly | Yes |
How to organise ongoing screening
- Keep one clean list of all active customers and suppliers, with the identifying data collected at onboarding.
- Decide the frequency based on your risk: daily for international trade or sensitive sectors, never less than the frequency your bank or regulator expects.
- Check owners and directors, not only company names.
- Define who reviews alerts and within what time.
- Record every result and decision, including the ones where nothing was found.
The hardest part is not the first run but the repetition. A process that depends on someone remembering to export the list and search it again tends to slip during busy weeks, which is exactly when new designations are often published.
What happens when a match appears
A new possible match on an existing customer needs a quick decision: verify the identifying data, stop pending payments or deliveries if the match looks real, and follow the reporting rules of the authority concerned. Our guide on what to do if a customer is added to a sanctions list describes these steps.
Where Unicorn Intelligence fits
Unicorn Intelligence compares every company in your CRM with the official lists every day and alerts you only when something changes; new accounts receive a $50 credit.
Frequently asked questions
Is a sanctions check at onboarding enough?
No. It is valid only for the day it is run. Lists change throughout the year, so existing customers and suppliers need to be checked again.
How often do sanctions lists change?
Authorities can add or remove names on any working day. In periods of international tension large packages of names are added at once.
How often should I re-screen my customers?
It depends on your risk. Companies in international trade or sensitive sectors often screen daily; in any case the interval should match what your bank or regulator expects.
Should I record checks that found nothing?
Yes. A record of clean results shows that the process ran regularly, which matters as much as the record of matches.
Do I also need to check owners again?
Yes. Owners change, and a new owner may be listed. Ongoing screening should cover the main owners and directors as well as company names.
Unicorn Intelligence is an information tool. Decisions and legal obligations, including sanctions compliance, due diligence and tender participation, remain with the customer.
Try Unicorn Intelligence: $50 welcome credit, used before any charge
Get startedSee pricesAbout the service: Sanctions and counterparty screening
Valid 90 days; once per account. No card until the credit is used up; then usage is charged to a card every week.