Sanctions and asset freezing framework

Asset freezing measures apply immediately and without any threshold. A designated customer or beneficiary who slips through screening exposes your institution to sanctions and to immediate reputational damage. Supervisors expect a complete framework, with documented calibration choices, that can demonstrate every decision.

I help you set up or review your sanctions and asset freezing framework, from list selection to alert handling, so that it works day to day and stands up to an inspection, with evidence and an audit trail.

Is this your situation?

• You are launching a new business line or product and need to build screening from day one.

• You are changing your screening tool or want to review its calibration.

• Your teams are overwhelmed by false positives, or your tool hardly generates any alerts at all.

• An inspection, an audit or your parent company has found weaknesses in asset freezing.

• Your framework relies on legacy practices, poorly documented, that no one can justify anymore.

• You need to cover sanctions regimes from several jurisdictions (France, European Union, United Nations, United States and, depending on your business, other countries).

This service is designed for banks and credit institutions, payment and e-money institutions, and insurers.

What the engagement covers

• The reference framework, meaning the applicable regimes and lists, your risk appetite and your sanctions policy.

• The screening scope, covering customers, beneficial owners, authorised representatives, counterparties and transactions.

• Tool calibration (thresholds, matching rules, lists, frequency) and the rationale for each choice.

• Alert handling, with levels of review, criteria for clearing potential matches, timeframes, escalation and traceability.

• Freezing measures and reporting to the competent authorities, with clear decision-making governance.

• Procedures, and their consistency with actual practice.

• Ongoing controls, with screening tests, sampling, indicators and reporting to senior management.

• Training for the teams handling alerts and for senior management.

Two formats

Set-up. For a new institution, a new business line or a new tool, I build the framework end to end, from scoping to roll-out, with your business, compliance and data teams.

Framework review. For an existing framework, I assess its coverage, calibration and alert handling, then deliver prioritised findings and a realistic action plan, which I can then implement with you.

How the engagement works

1. Scoping. An initial call to understand your business, flows, tools and deadlines, followed by a tailored proposal.

2. Assessment. Review of the lists, screening scope, calibration, a sample of alerts and existing documentation.

3. Implementation. Policy, procedures, calibration, alert handling workflow, controls and training, with your teams.

4. Evidence and audit trail. Calibration rationale file, traceable decisions, monitoring indicators and preparation of your exchanges with the supervisor.

What drives the scope

Every situation is different. The scope depends in particular on

• your business, products and countries of operation;

• the volume of customers, transactions and alerts;

• the screening tool used and how far it has been calibrated;

• the state of existing documentation;

• your deadlines (launch, inspection, tool change).

This is why each engagement is based on a proposal built after an initial call, tailored to your context. You receive it within 48 hours of our call.

Why Studio Compliance

• 25 years of experience in compliance and financial crime prevention, across traditional banking and fintech.

• Hands-on experience of setting up sanctions frameworks end to end, from scoping to ongoing controls, at an insurer and at payment companies.

• Experience working with data and product teams to design or calibrate alerting tools.

• CAMS certified (Certified Anti-Money Laundering Specialist) and board member of the ACAMS France Chapter.

• A pragmatic approach, with actionable, prioritised and documented recommendations.

• Strict confidentiality, with a non-disclosure agreement (NDA) available from the first detailed discussion.

Frequently asked questions

What is the difference between asset freezing and international sanctions?

Asset freezing is one of the restrictive measures provided for by sanctions regimes. A complete framework covers asset freezing as well as the other restrictions that may apply to your business, depending on your products and countries of operation.

Is our screening tool enough?

The tool is essential but it is only part of the picture. Supervisors also look at the screening scope, the rationale for calibration, the quality of alert handling and the traceability of decisions.

How can we reduce false positives without taking risks?

By adjusting calibration in a documented and tested way, and by organising alert handling around clear criteria. Every setting must be explainable to the supervisor.

Can you start quickly?

Yes. The initial call helps me understand your situation and propose a start that fits your deadlines.

Will our situation remain confidential?

Yes. Confidentiality is a basic condition of every engagement, and a non-disclosure agreement (NDA) can be signed before the first detailed discussion.

A launch, a tool change, an upcoming inspection?

An initial call is the best way to review your framework and define the next steps. Write to contact@studio-compliance.com or use the contact form.