Sanctions screening for travel companies

• The guest is not the payer: bookings made by a company, an agency or a family member mean the traveller and the payer are different people, and both matter.
• Corporate clients: negotiated rates and travel accounts are commercial relationships with companies whose owners are not visible from the contract.
• Channel partners: agencies, tour operators, destination management companies and affiliates are counterparties in their own right.
• Suppliers abroad: hotels, transport providers and local partners in many jurisdictions, some of them subject to sanctions.
• High-value and cash payments: large or cash payments can raise questions about where the money comes from.
• Speed: bookings and check-ins happen quickly and are handled by staff who are not compliance analysts.

1. 1

   Map the exposure

   Identifying who the business deals with and pays: guests, payers, corporate clients, channel partners and suppliers, and which sanctions regimes apply to each.

2. 2

   Screen counterparties

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

3. 3

   Screen bookings where the risk calls for it

   Screening of guests and payers on bookings that the business's own risk assessment flags, such as high-value, group or corporate bookings.

4. 4

   Re-screen

   Checking clients and partners again when lists change, because a counterparty can be designated after the relationship starts.

5. 5

   Keep the evidence

   A record of who was checked, when and with what result, so the business can show what it knew if a booking is questioned.

Anti-money laundering law usually does not name travel and hospitality businesses. Sanctions law applies to everyone: the UN, EU, UK and US regimes prohibit dealing with the funds of designated persons and making funds available to them, directly or through companies they own or control. Accepting a booking payment from, or paying, a designated person or company can breach these rules, whatever the sector.

Some sanctions regimes also restrict travel-related business with particular countries, and many combine asset freezes with travel bans on designated people. A travel business can also come within anti-money laundering rules through a regulated activity of its own, such as currency exchange, or through national rules on large cash payments, so it should check the rules where it operates. Where an AML duty does apply, the FATF Recommendations on customer due diligence and suspicious transaction reporting are the framework most national rules follow.

• Speed and simplicity: a real-time API that returns a clear result inside a booking flow, without interpretation at the front desk.
• Matching quality: fuzzy matching across transliteration and aliases, so a passport spelling does not become a miss.
• Ownership: KYB that looks through corporate clients and partners to their owners and applies rules such as the OFAC 50 Percent Rule.
• False positives: dates of birth and nationality used to rule out namesakes, so travellers are not held up by common names.
• Batch re-screening: the client and partner base re-checked when lists change, with alerts only on changes.
• Data handling: control over where guest data is processed and how long screening records are kept.