Sanctions QA
Your analyst
cleared the alert.Does the evidence
support that
decision?
The sanctions pilot re-tests completed alerts against your policy. Inspect the rationale, identify unsupported clearances and preserve the evidence behind the finding.
Examine a cleared-alert caseunsupported.
How a pilot runs
Run assurance without replacing the workflow.
01 / Map
Map current policy and QA.
Understand screening vendors, escalation logic and the evidence each decision leaves.
02 / Sample
Sample historical decisions.
Risk-based sampling across closed alerts and decision-makers, configurable up to the whole population.
03 / Re-test
Re-test independently.
Apply policy-aligned criteria to the original evidence and reasoning, by a reviewer not involved in the decision.
04 / Evidence
Produce the finding record.
A traceable, defensible audit trail showing what was reviewed and where exceptions were identified.
Scope, data access, review responsibilities and commercial terms are agreed before a pilot begins.
Assurance questions
Designed around the questions assurance teams already ask.
- Name variationWere spelling variation, transliteration, titles and suffixes tested?Review
- Disposition rationaleDoes the reasoning support the decision on the source evidence?Review
- EscalationWas the case escalated consistently with policy?Pass / Fail
- Vendor assuranceCan the firm demonstrate independent oversight of the screening outcome?Evidence
Regulatory context
What the FCA found in May 2026.
The FCA’s review of sanctions systems and controls assessed over 150 firms. It named as good practice “periodic testing and quality assurance of alert investigations”, and as poor practice “failure to meet internal SLAs for alert management and/or not operating effective quality control procedures”.
On causes of reported breaches it recorded “handling errors leading to alerts being incorrectly resolved”. On third parties: “firms relying on external or intermediary screening solutions without sufficient internal oversight or assurance”.
Source: FCA, 28 May 2026. Sanctions systems and controls: our firms, our findings
Next step
Start with your closed alerts.
The conversation opens with how sanctions QA runs in your firm and which decision-maker you are least sure about.