“The screening came back clear.” I’d still have questions.

After more than 17 years in sales and business development, I understand why people want a deal to move forward. Someone has spent months building the relationship. The customer is ready. There is a launch date, a revenue target and a team waiting to deliver.

Then compliance asks another question.

I can appreciate the frustration. But when a business says, “The screening came back clear,” my next question would be: what exactly have we established?

We may have checked the names provided against a sanctions list. That is useful. It does not, by itself, explain who controls the business, why another company is making its payments or who ultimately benefits from the transaction.

Those questions matter when looking at both money laundering and sanctions evasion.

A perfectly ordinary-looking payment

Consider a hypothetical example.

A payments company is onboarding a distributor. The registration documents are available, the named directors produce identification and screening finds no sanctions match.

Before the first transaction, the distributor asks whether an associated company can pay on its behalf.

There may be a perfectly reasonable explanation. Group treasury arrangements exist. Businesses use agents and intermediaries for legitimate reasons.

But I would want to understand the relationship. Does the payer belong to the same group? Does the explanation fit the contract? Can the customer support it with evidence?

The difficulty begins when the explanation is accepted because everyone wants to get the payment moving, rather than because it has been understood.

Nothing in this example proves wrongdoing. It does reveal an unanswered question.

AML and sanctions need different questions

An AML review might ask whether the payment makes sense for the customer’s business and whether there are grounds to suspect criminal proceeds.

A sanctions review also needs to establish whether a restriction applies to the parties, their ownership or control, or the activity involved. A legitimate source of funds does not settle that question.

Under UK guidance, an entity can be subject to asset-freeze restrictions because it is owned or controlled by a designated person, even when the entity itself does not appear on the sanctions list. A name check alone therefore cannot resolve the assessment. Other jurisdictions require their own analysis. [1]

FATF’s 2025 report on proliferation financing and sanctions evasion identifies intermediaries and concealed beneficial ownership among the methods used by evasion networks. My reading is that firms need to understand relationships between parties, alongside checking their individual identities. [2]

Who sees the whole transaction?

This is the question I would put to a business preparing to enter a new market.

Your onboarding team may understand the customer. Your local partner may see the payer. Your banking provider may see the settlement instructions.

Who can bring those pieces together?

For a fintech building a cross-border service, I would want that answered before launch. Who investigates an unexplained third-party payment? Who can obtain further ownership information? Who has authority to stop a transaction while a concern is assessed?

An agreement that says “the partner handles compliance” leaves too much room for different interpretations.

Make room for judgment

I would be cautious about treating every unusual arrangement as suspicious. Growing up in Togo and building my career in the UK has made me interested in how people explain business across different settings. An unfamiliar practice deserves a fair hearing.

It also deserves proper scrutiny.

The practical discipline is to hear the explanation, test it against the evidence and record why the conclusion makes sense. Where a material question remains unresolved, someone needs to own the next step.

For me, that is where useful compliance begins: helping a business understand enough to make a responsible decision, even when the commercial pressure is to move quickly.