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AFB Practice Roundtable: Identifying Customer Risk Using Real-Time Risk Scoring – Approaches to PEPs, Sanctions and Watchlist Screening

In 2024, the geopolitical context is evolving rapidly and there is a renewed focus on sanctions against Russia and state supporters of extremist groups. As a result, banks will face increased complexity when it comes to screening, onboarding, and servicing customers. This is particularly the case for firms operating in the UK as the FCA has signalled concerns about a potential ‘one size fits all’ approach to PEP screening in particular.

What does the regulatory framework in the UK mean for foreign (non-UK) PEPs and the institutions that service them? How do firms need to adjust risk assessments for both retail and wholesale customers? Should banks review screening and transaction monitoring measures for exposure to sanctioned entities and individuals?

This practice roundtable, in partnership with ComplyAdvantage, will provide an opportunity for members with each other to discuss the unique challenges facing non-UK banks in this area. Members will hear from ComplyAdvantage on how real-time customer risk scoring can help reduce uncertainty in times of change.

The Chatham House Rule will apply to this event to encourage open dialogue and discussion.

PEPs, sanctions and watchlist screening is an area of particular importance. In ComplyAdvantage’s recent industry research, 79 percent of UK banks shared that they will be reviewing their PEP risk management this year because of planned elections.      This includes, for example, applying greater due diligence at onboarding and tighter ongoing monitoring. Further, a third of survey respondents highlighted geopolitical situations as a concern.

Who should attend?

This roundtable will be particularly valuable for MLROs, Heads of Compliance/Chief Compliance Officers who are responsible for managing the PEPs, sanctions screening and risk management policies and frameworks within their firms.

AFB will circulate an agenda and series of questions to attendees in advance which will be used to aid discussions.

There will be refreshments and networking from 8:30, before the discussion starts at 9:00.

Please note that capacity for the roundtable is limited to 30 members, one person per member bank.

What will members gain for use at their bank?

  • Practical guidance on how to leverage customer, PEP, and sanctions data to create a holistic view of risk
  • An understanding of the UK regulatory requirements, upcoming changes and the risk factors firms will need to consider when onboarding and managing PEP relationships
  • Practical guidance on how to balance internal challenges that arise from differing – and sometimes conflicting – due diligence requirements across jurisdictions
  • An awareness of the steps banks can take to achieve the required level of due diligence within a risk-based approach, without creating friction in client relationships
  • An opportunity to discuss key challenges and network with peers


Alia Mahmud, Regulatory Affairs Practice Lead

Alia is a qualified risk and compliance professional with over a decades experience working with global financial institutions and FinTech’s, advising on legal, risk and compliance processes to deliver cross-business innovative control solutions.

Completing her undergraduate in Law from the London School of Economics and Legal Practice Course followed by a Master of Law from BPP University, she started her career in criminal law as a trainee solicitor. With a mission to proactively disrupt organised crime and help reduce the myriad of financial crimes taking place, she transitioned to a career in financial crime and regulatory compliance at Lloyds Bank, HSBC, Qatar National Bank, Oaknorth, Revolut and Algbra, to be at the frontline in combating financial crime risks and safeguarding organisations and communities from being used and abused by criminal organisations. As part of the Global Regulatory Affairs team at ComplyAdvantage, Alia supports product, marketing and commercial teams with building world-leading financial crime detection tools and is the ‘voice of the customer’ as Customer in Residence and Regulatory Affairs Practice Lead.

Iain Armstrong, Regulatory Affairs Practice Lead

Iain Armstrong is a Regulatory Affairs Practice Lead at ComplyAdvantage. Iain has held a number of senior compliance roles in major financial institutions, including NatWest, HSBC, and Barclays. Iain also spent eight years working at the UK’s Financial Conduct Authority.


Fee:            Included in AFB membership (no fee)

Location:   ComplyAdvantage, 2nd Floor, Fetter Yard, 86 Fetter Lane, EC4A 1AD

Date:          Wednesday, 17 April 2024

Time:          09:00-10:30 (arrival from 08:30)

If you would like to submit a question before or have any specific areas that you would like the session to address, please send them to the AFB at You will receive details on how to join the session one week before the event.

Sponsored by


ComplyAdvantage is the financial industry’s leading source of AI-driven financial crime risk data and fraud detection technology. ComplyAdvantage’s mission is to neutralize the risk of money laundering, terrorist financing, corruption, and other financial crime. More than 1000 enterprises in 75 countries rely on ComplyAdvantage to understand the risk of who they’re doing business with through the world’s only global, real-time database of people and companies. The company identifies thousands of risk events daily from millions of structured and unstructured data points.

ComplyAdvantage has four global hubs in New York, London, Singapore, and Cluj-Napoca and is backed by Goldman Sachs, Ontario Teachers, Index Ventures, and Balderton Capital.

Learn More on the ComplyAdvantage Website