Sanctions and PEP screening for AU Tranche 2 practices

What sanctions screening must cover

AUSTRAC's expectation is that reporting entities screen each customer (and each natural person in a customer's beneficial-ownership chain) against the relevant sanctions and PEP lists at the point of engagement and on an ongoing risk-based cadence. The relevant lists for an AU practice include DFAT's Consolidated List, OFAC, the EU Consolidated Financial Sanctions List, the UN Consolidated List, and major PEP and SIP databases.

Screening is not a one-off check. Sanctions lists change weekly; PEP statuses change with elections and appointments. A customer who screened clean at engagement may not screen clean six months later. Re-screening is the mechanism that catches those changes.

How Caltury handles screening

Caltury integrates with OpenSanctions, which aggregates over 150 sanctions and PEP lists into a single searchable database. Screens run at customer intake automatically and re-run on the cadence the customer's risk band requires (high 6-monthly, medium annually, low every 3 years).

Hits are surfaced in the customer file with the underlying source list, the match confidence, and the data point that triggered the match. The named Compliance Officer reviews each hit and records the decision (false positive, escalate, file an SMR, disengage). The decision and the underlying screen are retained for the 7-year retention period.

Coverage: DFAT, OFAC, EU, UN, plus PEP and SIP databases (150+ lists)
Screens at intake, plus risk-based re-screen cadence
Hits surfaced with source list, confidence, and matching data
Compliance Officer review workflow with documented outcome
Hits and decisions retained in audit log for 7 years

Cost and limits

Sanctions screening is bundled in the Caltury subscription. There are no per-screen surcharges on Starter (A$99/mo), Practice (A$249) or Firm (A$499). Re-screens, beneficial-owner-chain screens, and ad-hoc screens against the same customer all run without additional charge.

The screening engine is hosted in Sydney (Supabase ap-southeast-2). Screen latency is typically sub-second. There is no rate limit at any standard tier.

Common questions

Why use OpenSanctions over a single regulator's list?

DFAT alone covers Australian autonomous sanctions but not the full set of UN, OFAC and EU measures Australia recognises. OpenSanctions consolidates the relevant lists. Screening only against DFAT would miss material exposure.

What about false positives? Common names will hit.

Common-name false positives are surfaced with low match confidence and contextual data (DOB, country, source). The Compliance Officer marks the hit as a false positive with a brief reasoning note; the note is retained for the audit period. Caltury does not penalise practices for false-positive volume; the rate is what it is for any name-based screen.

Can I screen ad-hoc, outside the normal cadence?

Yes. Any user can trigger an ad-hoc screen on any customer at any time. Common scenarios: a press story breaks involving a known PEP, a customer's circumstances change, a new beneficial owner is identified mid-engagement.

Do you screen against adverse-media lists?

Adverse-media screening is on the roadmap. Today, OpenSanctions covers the regulatory list set comprehensively. Adverse-media is supplementary and useful but not mandatory under the Act.