The Growing Imperative for Continuous Sanctions and Fraud Monitoring

Over the past decade, the complexity of global sanctions regimes and the sophistication of financial crime networks have grown exponentially. One-off screenings at onboarding simply can’t keep pace with new listings, updated politically exposed person (PEP) statuses, or emergent adverse media about individuals or entities. Today, continuous monitoring is the benchmark for proactive risk management and regulatory compliance in financial services, security-sensitive sectors, and beyond.

High-Profile Compliance Failures Highlight the Stakes

Standard Chartered Bank’s £102.2 million FCA fine (2019)
In 2019, the UK’s Financial Conduct Authority fined Standard Chartered Bank £102.2 million for “serious and sustained shortcomings” in its anti-money laundering (AML) controls, notably its failure to maintain effective ongoing monitoring and due diligence in higher-risk business areas, including certain branches in the UAE.

HSBC’s multi-billion-dollar penalties (2012 & 2021)
In 2012, HSBC Bank USA paid the US Comptroller of the Currency a $500 million civil money penalty for AML failures, including deficient transaction monitoring. In 2021, the FCA fined HSBC £63.9 million for “serious weaknesses” in its automated monitoring, leaving entire regions (e.g., Wales) unmonitored and delaying Suspicious Activity Reports by years.

Danske Bank’s Estonian branch scandal
In 2022, the Central Bank of Ireland fined Danske Bank A/S €1.82 million for deficiencies in transaction monitoring under the Criminal Justice (Money Laundering & Terrorist Financing) Act 2010 - part of wider sanctions and AML probes that ultimately cost Danske more than $2 billion in US and Danish penalties for laundering hundreds of billions of euros through its Estonian arm.

These examples underscore the reputational, operational, and financial damage inflicted when continuous monitoring is neglected.

Cross-Industry Compliance Failures

Rideshare operators
Between 2016 and 2019, a Somali national found liable in US courts for war crimes was driving for major rideshare platforms because initial criminal checks found no US convictions. A global watchlist check, or periodic re-screening, would have flagged his name on human-rights-related sanctions lists.

Airport security
For nearly 20 years, one of Dulles International Airport’s unarmed security guards hired through a third- party contractor, was a former Somali military commander accused of atrocities. He passed FBI and TSA vetting, but continuous global watchlist monitoring would have identified him immediately.

Healthcare providers
In early 2025, an addiction treatment centre in Utah and an Ohio nursing facility each paid six-figure penalties after employing staff excluded by the US HHS-OIG from federal healthcare programmes. Ongoing monthly exclusion-list monitoring would have prevented these violations. Similarly, several US hospitals and pathology labs were fined in 2024 for hiring excluded individuals, highlighting the insufficiency of one-off checks.

Together, these cross-sector incidents show that continuous monitoring is essential not only in banking but wherever personnel or partners interact with sensitive assets, regulated products, or high-risk jurisdictions.

Regulatory Mandates Across Industries

Financial Services & AML
Since the Money Laundering Regulations 2007, UK firms have been required to implement transaction monitoring systems capable of detecting suspicious activity; continuous screening of customers against sanctions and PEP lists became compulsory upon its introduction. Subsequent updates, including the Fifth Anti-Money Laundering Directive, mandate enhanced due diligence and ongoing review of existing clients whenever their risk profile changes.

Politically Exposed Persons (PEPs)
Both UK and EU regulators demand rigorous PEP screening at onboarding and periodic re-screening to capture changes in political status, affiliations, or emerging adverse news. The FCA’s ongoing review of PEP definitions and risk assessments, expected to conclude in mid-2024, highlights the continued emphasis on real-time and scheduled re-assessments.

BS7858 Security Screening
Under BS7858, the British Standard for security screening of roles with access to sensitive assets or data, organisations must conduct ongoing monitoring throughout employment, including periodic re- screening to ensure personnel remain compliant with the standard’s criteria.

Introducing Verifile’s Continuous Monitoring Service

Verifile’s Global Fraud & Sanctions Monitoring Service delivers a fully managed, cost-effective monthly screening solution designed to keep your employee or customer profiles continuously up-to-date against global watchlists, sanctions data, PEP registers, and adverse media sources.

1. Secure File Exchange
   • We provide a template for profile data.
   • Clients upload their file to a dedicated SFTP site that ensures safe, automated transfer of profile data each month.
2. Automated & Manual Hybrid Processing
   • Verifile retrieves the file the next working day.
   • Automated screenings run, followed by manual expert review to minimise false positives.
3. Fast Turnaround
   • Results are delivered via the same SFTP site within three working days of retrieval.
   • Comprehensive reports enabling swift action on any alerts.
4. Feedback-Driven Refinement
   • Client feedback is integrated into our screening engine, continually reducing false positives over time.
   • Verifile fine-tune the screening engine and further slash false positives over time.
5. Flexible Profile Management
   • Annual package covers as many profiles as required (with allowance for profile changes included).
   • Additional profiles can be purchased as needed.

This structured, transparent model ensures you capture new sanctions listings, PEP updates, and media exposures as they occur and far beyond the capabilities of static, point-in-time checks.

Real Business Value

1. Risk Mitigation

   Continuous monitoring identifies emerging risks before they escalate, protecting against fines, legal actions, and reputational harm.

2. Regulatory Confidence

   Demonstrate ongoing compliance with FCA guidelines, AML directives, and industry standards like BS7858.

3. Resource Efficiency

   Outsourcing to Verifile’s managed service frees up internal compliance teams to focus on high-value investigations rather than routine screening tasks.

4. Scalability & Agility

   Easily add or remove profiles to reflect organisational changes, whether you’re scaling up, restructuring, or onboarding new regions

5. Data-Driven Insights

   Regular reporting and analytics offer clear visibility into screening trends, alert volumes, and risk profiles across your entire population.

6. Flexible Deployment Models

   Choose between fully managed or self-service screening options, with tiered pricing discounts that make continuous monitoring accessible and cost-effective for any budget.

Who Benefits Most?

• Finance & Insurance Firms

  Subject to strict AML and sanctions regulations, these firms use continuous monitoring to avoid regulatory breaches and maintain customer trust.

• Security & Critical Infrastructure

  Organisations adhering to BS7858 rely on ongoing personnel screening to protect facilities and sensitive data.

• Corporate Enterprises

  Multinationals with global workforces need to spot emerging risks, like sanctioned counterparties or adverse press, before they escalate.

• Third-Party Risk Managers

  Procurement and vendor management teams screen suppliers and partners continuously to prevent supply-chain exposure to sanctioned entities.

Getting Started

Verifile’s Continuous Monitoring Service is priced per profile per month, plus a managed service fee per month, payable annually in advance for a 12-month term. Once your data feed is established via SFTP, Verifile handles the rest: delivering peace of mind that your compliance programme is always current, always vigilant, and always aligned with global best practices.

To learn how Verifile can empower your organisation with continuous, expert-driven monitoring, contact our team today and turn regulatory challenges into competitive advantage.