Sanctions lists and PEP databases only capture what someone has officially recorded. Many risks appear on no list: ongoing criminal proceedings abroad, involvement in a corruption case, a corporate insolvency with allegations against the directors. Adverse media screening looks for these signals in publicly available sources.
What counts as relevant
Relevant reports are those linked to money laundering and its predicate offences: fraud, corruption, tax offences, organised crime, sanctions evasion, human trafficking, environmental crime. Irrelevant is anything merely unpleasant — a dispute over a building permit or criticism of a business model. The line belongs in the internal directive; otherwise everyone decides by gut feeling.
Weighing sources
Not every hit is worth the same. A report by an established newsroom referring to court files weighs more than an anonymous blog post. A ten-year-old allegation that ended in acquittal is assessed differently from an indictment this year. Good practice records which source was found, how it is assessed and what follows: nothing, a question to the client, enhanced due diligence or rejection.
Proportionality
How deep the research goes follows the risk-based approach. For a locally active person with a transparent source of wealth, a basic search suffices. For a person with political exposure, links to high-risk countries or a complex structure, a deeper search is appropriate, including in the languages and media of the countries concerned.
Data protection
Under the Swiss Federal Act on Data Protection, data on administrative and criminal proceedings and sanctions is sensitive personal data. That does not prohibit the research, which is justified within statutory due diligence. It does call for restraint: collect only what the assessment needs, restrict access and do not reuse results for other purposes. See our article on data protection in the family office.
Once or ongoing
Screening at onboarding is the start. For higher-risk relationships, a repeat belongs in the periodic review, and for legacy books in KYC remediation. A hit noticed years after the report is a control failure, not bad luck.