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Overview

This guide outlines the various lists that flag in our Sanctions category, including FATF country ratings along with our data validation approach to ensure our lists are always up to date.

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How does Minerva perform Sanctions screening?

When the Sanctions data category is selected during the search process, Minerva performs in-depth screening of all critical globally recognized sanctions designation lists using the legal name of the individual or organization being searched. By adding additional information to the search such as date of birth (individuals) or registration number/date of registration (organizations), this will increase the probability of a potential match and help to manage false positives. For all searches, the Sanctions Screening List section of the report provides a detailed listing of all the sources that were screened as part of the search regardless of outcome. Here are the key Sanctions and Watchlists that Minerva scans when the Sanctions feed is selected during a search. The following list is not comprehensive:
  • Canada
    • Canadian Autonomous Sanctions List which includes:
      • Justice for Victims of Corrupt Foreign Officials Regulations (JVCFOR - Canada)
      • Special Economic Measures Act List (SEMA – Canada)
      • Freezing Assets of Corrupt Foreign Officials Act (FACFO Act –Canada)
      • Listed Terrorist Entities (groups and individuals) designated under the Regulations Establishing a List of Entities (RELE – Public Safety Canada, often referred to as Criminal Code or SOR 2002/284)
  • United States
    • International Trade Association Consolidated Screening List (13 key sanctions lists including the BIS, SDN and Non-SDN Lists)
    • Consolidated Sanctions List (Non-SDN) List
    • Specially Designated Nationals (SDN) List
    • Bureau of Industry and Security (BIS) Denied Persons List
    • FBI “Most Wanted” (Watchlists)
    • Hijack Suspects List
    • Terrorist List (includes Domestic Terrorists)
  • Australia
    • Department of Foreign Affairs and Trade (DFAT) Consolidated Sanctions List
  • European Union
    • European External Action Service (EEAS) Sanctions List
  • FATF (Watchlists)
    • Blacklisted (High Risk) Jurisdictions
    • Greylisted (Increased Monitoring) Jurisdictions
  • France
    • France uses a single list that includes the EU (EEAS) and UN lists along with the France National Assets freezing lists found at the Ministry of Economics and Finance – France DG Tresor list
  • Switzerland
    • Swiss State Secretariat for Economic Affairs (SECO) Sanctions List
  • Ukraine
    • Ukraine State Financial Monitoring Service (SDFM) Blacklist
  • United Kingdom
    • Her Majesty’s Treasury Sanctions List
  • United Nations
    • United Nations Security Council Consolidated List (UNSC List) – Used by UN member nations (e.g., Canada, EU etc.)

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List Update and Management Process:

Minerva makes it easy for customers to stay up to date with the rapid pace of sanctions list changes. By automatically ingesting and updating each list nightly, directly from its source, we ensure that the most current information is available for our customers. Data ingestion logs are reviewed bi-weekly to ensure there are no loading errors and lists are sample tested (internally audited) at least once per year.

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Internal Testing Process

When a new list is ingested: In our QA environment, a random sample of 5-10 individuals and entities that are “positively identified” on each list is selected and searched with the expected result of a Sanction flag. Reports are generated and the report audit trail is validated to ensure that the referenced list information within the report is correct. Screenshots are taken and stored with each test case. A control sample of subjects who should not appear flagged for sanctions is also reviewed. Once the testing has been approved in the QA environment, it is promoted to the production environment.

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Ongoing Validation

In our Production environment, for each list, a random sample of 5-10 individuals and entities (as applicable) that are “positively identified” are selected and searched with the expected result of a Sanction flag. Where the subject has been removed, we would expect to see no sanction flag for that search result. Reports are generated and the report audit trail is validated to ensure that the referenced list information within the report is correct. Screenshots are taken and stored with each test case. A control sample of subjects who should not appear flagged for sanctions is also reviewed.

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FATF Countries Lists

FATF lists are updated manually. Minerva belongs to the FATF notification system and proactively checks the FATF lists monthly. Once the list is updated, Minerva uses the testing approach referenced to sample 2-5 individuals or entities from each added or removed country and confirms alignment to the correct score within the risk rating (High Risk, Increased Monitoring).