FINMA expectation since 2024: 24-hour sanctions screening

Sanctions screening has become a distinct compliance discipline that requires auditable processes.

ACTAN SanctionsCheck enables automated and continuous sanctions screening across the entire client base, with traceable screening reports, lean operational implementation, and predictable flat pricing.
Primarily for small and mid-sized asset managers in Switzerland. Also suitable for trustees.
SECO + OFAC    ·    Hosting in Switzerland    ·    ISO 27001-based infrastructure    ·    ACTAN AG, FINMA-licensed since 2023
Built for ongoing sanctions screening

Why sanctions screening now requires a dedicated tool

The key change is not that sanctions screening is new. What is new is that FINMA has significantly tightened its expectations since 2024. What previously ran alongside other periodic or risk-based compliance reviews now requires its own time-sensitive and traceable process.
Until 2023
In many firms, sanctions screening was carried out together with other periodic or risk-based compliance reviews. A dedicated process, its own review frequency, or a dedicated tool was often not required.
Since 2024
FINMA has significantly raised its expectations regarding response times and process quality. New sanctions entries are expected to be screened against the entire client base promptly, on a best-effort basis within 24 hours.
Today
Sanctions screening is therefore no longer just one element of broader compliance reviews. It now represents a distinct discipline, with its own frequency, its own process, and the need for a lean, ongoing tool.
Source: FINMA review points on compliance with anti-money laundering requirements (AML review points for banks and asset management, question E7). Supported by Grant Thornton Switzerland/Liechtenstein (May 2025) and Peak Compliance.
What previously often ran manually alongside other compliance reviews now requires its own ongoing and traceable process, one that can be implemented in an operationally sustainable and economically proportionate way.

Others can do this too. But usually with a different cost and operating model.

Established compliance providers have responded to the new requirements and now also offer ongoing sanctions screening. Today, the difference often lies less in technical feasibility than in the question of the size at which these models make economic sense, and whether a dedicated tool for the sanctions component is the better fit.
Multi-discipline tools
Bundle sanctions, PEP, adverse media, and KYC into one comprehensive solution. In many products, the sanctions component has now also been extended to ongoing screening. For smaller and mid-sized independent asset managers, however, entry thresholds and pricing often sit well above what is proportionate for the sanctions component alone.
PEP, adverse media, and KYC can still be covered effectively in this way, even where a more focused tool may be the better fit for sanctions.
Managed services
Take over sanctions screening as an external service, in some cases now also on an ongoing basis. Pricing models are often usage-based or mandate-based and tend to increase as the client base grows. Operationally, this means greater external involvement and, depending on the setup, a different regulatory positioning.
For some firms, this can be a sensible model. Many, however, prefer to keep the sanctions component deliberately within their own process.
Addition, not replacement
In many firms, ACTAN does not replace the existing compliance solution. It complements it specifically for the sanctions component. Existing solutions remain in place for PEP, adverse media, and KYC. ACTAN is added for ongoing sanctions screening.

We focus on sanctions screening, and we cover it fully.

ACTAN SanctionsCheck is a focused tool for ongoing sanctions screening, designed to support your own process rather than act as an outsourced service. You keep control in-house, whether you perform the screening for your own firm or on behalf of your mandate clients.
What we cover
Ongoing sanctions screening against SECO and OFAC lists
Automated screening of the entire client base within 24 hours
Audit-ready PDF report for every screening run
Whitelist function to reduce recurring false positives
What we don't do
No KYC system and no onboarding workflow
No PEP screening, no adverse media screening, and no crime database
No risk scoring of your clients
No substantive assessment of matches. The decision remains with you

Designed so that a classic outsourcing notification is typically not required

ACTAN SanctionsCheck is designed as a tool within your own process, not as the outsourced takeover of a key function. For many firms, this results in a significantly lower regulatory entry barrier.
In-memory processing
Client data is processed in memory only for the duration of the screening and is not stored permanently as screening data.
Swiss hosting
The infrastructure runs in Switzerland and supports a locally embedded operating model with clear data governance and short paths.
No outsourcing notification
ACTAN SanctionsCheck is designed as a tool within your own process. For many firms, this typically does not result in a classic outsourcing setup.
This architecture is designed from the outset to keep sanctions screening within your own process and thereby significantly reduce the regulatory entry barrier for many firms.

Pricing Overview

Starter Plan

$29

/month
or $24/month billed yearly
Perfect for solo founders and small teams just getting started.
Includes:
1 user seat
Automated payroll & tax filing
Real-time dashboard
5 integration connections
Email support
Built-in security & compliance layer
Starter Plan

Custom pricing

For large teams and regulated organizations with complex needs.
Includes everything in Growth, plus:
Unlimited user seats
Dedicated account manager
Custom integrations & API access
Onboarding and team training
Quarterly compliance reviews
SLA & 24/7 priority support
Starter Plan

$216

/year
or $18/month billed yearly
Perfect for solo founders and small teams just getting started.
Includes:
1 user seat
Automated payroll & tax filing
Real-time dashboard
5 integration connections
Email support
Built-in security & compliance layer
Starter Plan

Custom pricing

For large teams and regulated organizations with complex needs.
Includes everything in Growth, plus:
Unlimited user seats
Dedicated account manager
Custom integrations & API access
Onboarding and team training
Quarterly compliance reviews
SLA & 24/7 priority support
Paket Basislizenz pro Jahr Ø pro Name
For a more precise cost estimate, use the pricing calculator to calculate your license costs based on customer type, number of monitored names, and optional add-on modules.

Frequently asked questions

Is ACTAN SanctionsCheck suitable for FINMA-related requirements?

ACTAN SanctionsCheck was built for regulated financial intermediaries in Switzerland that need sanctions screening to be traceable, documented, and operationally efficient. The solution helps you screen relevant client data against current sanctions lists, review potential matches in a structured way, and maintain screening records for internal controls, supervisory organisations, or audits. The final regulatory assessment remains part of your own responsibility and organisational setup.

Does using ACTAN SanctionsCheck qualify as a reportable or licence-relevant outsourcing arrangement?

ACTAN SanctionsCheck is designed in a way that does not structurally resemble a classic, full outsourcing of your screening process. It serves as a tool for your own screening and documentation workflow. That said, the final regulatory classification always depends on your specific setup, internal processes, and contractual framework.

Where is my data processed, and what is actually stored?

Submitted screening files are processed for the purpose of the screening run and are not permanently stored as customer files. For operations, traceability, and contract administration, technical metadata, protocol information, and system logs may be processed. The architecture is designed to minimise data storage and to separate screening content from technical evidence.

Which lists are screened, and how up to date are they?

ACTAN SanctionsCheck screens against relevant sanctions lists such as SECO and OFAC. New list versions are incorporated on an ongoing basis so screenings are performed on a current basis. The screening report documents which list basis was used for each screening run.

How does a screening work in practice, and how long does it take?

You upload your file as an Excel or CSV file, or trigger screenings automatically as part of an automated workflow. The solution processes the names, presents potential matches in a structured format, and generates a screening report. The duration depends on the number of names and the number of potential hits. In practice, screenings are typically completed within a few minutes.

Do I need a system integration, or is Excel enough?

No system integration is required. ACTAN SanctionsCheck can be used without a CRM or core banking integration. For many organisations, a structured Excel or CSV export is sufficient. If you want to automate your workflow further later on, integrated and API-based setups are also possible.

What evidence do I receive for audit, supervisory review, or internal controls?

You receive a screening report containing the key evidence of the screening run, including timestamp, list basis, screening scope, and hit overview. This gives you a traceable basis for internal controls, supervisory reviews, audits, and compliance documentation.

How will I be informed about new SECO or OFAC updates?

When using the Client Agent, your client base can be monitored at regular intervals. As soon as a relevant change in the underlying sanctions lists is detected, a new screening can be triggered automatically. Notifications by email or SMS can also be configured.

Ready to discuss the right setup for your organisation?
Together, we define the right license tier, optional add-on modules, and the operating model that best fits your requirements.