Circumvention, by its very nature, is difficult to spot. Yet this is an important priority for regulators. Where a payment has been previously declined, it is vital that a similar payment, if represented in the future, is also declined. In order to improve the ability to detect circumvention, we work with organisations to:

• Improve self- and independent assessment processes to identify potential areas of concern in sanctions programs, including circumvention detection

• Develop both preventive and detective processes and tools and utilise visual analytics environments for examining large data sets to help financail institutions understand where future compliance risks and concerns may occur based on several different factors, such as historical issues, contextual data or industry-related events

• Improve overall governance and the level of management reporting available to measure progress against objectives and requirements.

• Check for suspicious patterns of characters in originator or beneficiary fields and for suspicious phrases usually used to conceal originator or beneficiary identity

• Identify similar payments that have already been blocked or rejected, and if circumvention has occurred, understand why and how it has occurred.

• Make recommendations to manage future circumvention activity