Sanctions screening for telecoms

• Subscribers at scale: prepaid and postpaid sign-ups, often through dealers, with little time for manual review.
• International partners: interconnect, roaming and wholesale partners in many jurisdictions, some of them state-linked.
• Resellers and distributors: dealer and reseller networks whose ownership is rarely obvious from the contract.
• Suppliers: network equipment and technology suppliers, where sanctions and export control rules can both apply.
• Payment-like services: mobile money, wallets and stored airtime value can bring payment and AML rules into play.
• Multilingual names: subscriber and partner names written in many scripts and transliterations.

1. 1

   Map the exposure

   Identifying where the operator deals with people and companies: subscribers, business customers, partners, resellers and suppliers, and which sanctions regimes apply to each.

2. 2

   Screen business counterparties

   Sanctions screening of partners, resellers and suppliers and their beneficial owners before contracts are signed and payments made.

3. 3

   Screen subscribers where the risk calls for it

   Sanctions screening of subscribers and business customers at sign-up, in line with the operator's own risk assessment and any national subscriber rules.

4. 4

   Re-screen

   Checking the existing base again when lists change, because a partner or customer can be designated after the contract starts.

5. 5

   Cover the adjacent rules

   Export control checks on equipment and technology, and AML controls for any payment or e-money service, usually handled with dedicated processes.

Anti-money laundering law usually does not name telecoms operators. Sanctions law applies to everyone: the FATF Recommendations on targeted financial sanctions (Recommendations 6 and 7) expect countries to require all persons to freeze the funds of designated persons and not make funds or services available to them, and the UN, EU, UK and US regimes each apply to the businesses within their reach. Some regimes also restrict specific telecoms services, equipment or technology for certain countries.

Where an operator offers mobile money or holds customer funds as stored value, that service may need payment or e-money authorisation and bring full anti-money laundering duties with it; FATF has published risk-based guidance on prepaid cards, mobile payments and internet-based payment services. Equipment and technology exports can fall under export control law, which is a separate regime from sanctions screening of people and companies.

• Volume: a real-time API for subscriber sign-up and batch screening for the existing base.
• Matching quality: fuzzy matching across transliteration and aliases for multilingual subscriber and partner names.
• Ownership: KYB that looks through partners, resellers and suppliers to their owners and applies rules such as the OFAC 50 Percent Rule.
• False positives: secondary identifiers used to rule out namesakes, so large subscriber bases do not flood the review queue.
• Explainable matches: every alert shows which list and record matched, so a decision can be documented.
• Clear scope: know which needs the tool covers and which, such as export control or transaction monitoring, need other processes.