Transaction screening still remains a cornerstone of sanctions compliance, but it only goes so far.

According to RegTech firm Quantifind, truly understanding sanctions exposure means looking past the names on a payment and examining the activity behind it: where the funds originated, what is being financed, and whether that activity is legally permitted at the moment the transaction takes place.

A string of sanctions developments in September demonstrated the point. Payments routed through third countries, new restrictions on Sudanese gold and changes to Iran-related authorisations each exposed gaps that list matching alone cannot close.

On 10 September, OFAC announced a $1.43m settlement with an individual over apparent breaches of Iran sanctions. The case involved Iranian-origin dividends paid into US bank accounts via banks in Türkiye, the UAE and Singapore. The individual had co-founded an Iranian software company, kept business ties with its leadership and bought four properties in Iran.

For banks, the lesson is clear: the immediate sender and originating bank may reveal little about the true source of funds. Investigators need insight into a customer’s source of wealth, business interests and how payment flows align with what the institution already knows.

Switzerland’s restrictions on Sudanese gold, also effective from 10 September, highlight a different challenge. The measures ban the purchase, import and transit of Sudanese-origin gold, as well as related services and financial assistance. Screening the buyer and seller does not settle the matter.

Institutions may need to establish the gold’s origin and determine whether their financing supports prohibited activity, a task that cuts across trade finance, customer due diligence and transaction monitoring.

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