Appropriate tuning must maintain the tool's ability to capture spelling variations, transliterations, and linguistic differences. This is essential for detecting sanctioned parties that may appear under alternate spellings (e.g., Arabic, Cyrillic transliterations).
Exact-match screening (C) or limiting variations (A, D) leads to missed true positives and violates regulatory expectations for effective sanctions screening.
Reference:
Wolfsberg Guidance on name-matching and spelling-variation recognition.
Importance of fuzzy and variant matching in sanctions screening systems.

Sanctions and Compliance Domains outline that references to sanctioned ports, locations, or shipping routes in payment instructions require further investigation. Even when the transaction parties are not located in a sanctioned jurisdiction, involvement of a sanctioned port or movement of prohibited goods can trigger sanctions exposure.
The correct approach is to obtain supporting documents such as shipping documents, invoices, bills of lading, and routing information to confirm whether the shipment, goods, transport path, or third parties have any sanctioned involvement. Approving or rejecting a payment without verification contradicts sanctions screening standards.
Reference from Sanctions and Compliance Domains:
Requirements to investigate references to sanctioned locations in trade or payment messages.
Guidance on obtaining underlying documents to assess sanctions exposure.
Expectations for verifying goods, ports, and shipment paths.

US sanctions and export-control laws apply to US companies and their owned or controlled foreign subsidiaries. Shipping dual-use items to Iran and falsifying end-user location information constitutes a serious sanctions violation and potential export-control breach.
Sanctions and Compliance Domains emphasize that upon discovery of such activity, the company must immediately cease the shipment of goods to sanctioned destinations and strengthen its sanctions compliance program. This must include enhanced oversight, stricter internal controls, and remediation of misconduct.
Reliance on subsidiary attestations or attempts to route transactions through non-US institutions does not eliminate US sanctions liability.
Reference:
US sanctions applicability to foreign subsidiaries of US companies.
Requirements for ceasing prohibited exports and implementing remediation.
Export-control restrictions on dual-use goods and falsification of end-use information.

An effective export compliance program must include formalized and documented screening procedures, including payment screening, trade documentation screening, and counterparty checks. This ensures compliance with sanctions, export restrictions, and embargo requirements.
Freight forwarders may assist but do not replace internal compliance responsibilities. Boycott-related terms must be avoided, and collecting vouchers is not an export controls safeguard.
Reference:
Export controls compliance requirements for systematic sanctions screening.
Internal control expectations for export transactions.

The Wolfsberg Guidance identifies that effective sanctions screening depends on high-quality, risk-relevant reference data. Institutions must regularly review and remove outdated or irrelevant data to avoid generating unnecessary alerts and ensure screening outputs remain meaningful. Maintaining accurate and current data reduces noise and increases the productivity of alerts.
The Guidance also emphasizes that institutions may use "good guy lists" to reduce false positives, but these lists must be maintained in a controlled way to ensure they do not unintentionally suppress alerts that could indicate sanctions risk. Proper governance must accompany good-guy lists so that risk-relevant entities are not excluded from screening.
The Guidance does not support reducing thresholds to generate more alerts, nor does it promote removing low-risk parties without structured criteria. It also does not recommend manual jurisdiction-specific screening as a method of improving alert quality.
Reference from Sanctions and Compliance Domains:
Wolfsberg principles on management of reference data for sanctions screening.
Guidance on proper use and governance of "good guy lists."
Recommendations for ensuring alerts remain relevant, accurate, and risk-based.