£160K is the current cost of customer screening failure
02/03/2026
Comsure published four detailed articles analysing the OFSI penalty imposed on Bank of Scotland for sanctions‑screening failures.
- The £160,000 penalty imposed on Bank of Scotland is a stark reminder that inadequate sanctions screening is no longer a technical glitch — it’s a direct regulatory breach with real financial and reputational consequences.
- OFSI’s findings show that even minor name-matching failures allowed a designated individual to move funds unchecked, resulting in 24 prohibited transactions.
- In today’s sanctions environment, anything less than robust, intelligent screening is simply unacceptable.
The Comsure articles break down:
- How a designated individual opened an account at Halifax on 6 Feb 2023 using a passport with spelling variations not detected by the bank’s automated screening.
- Why the sanctions screening system failed, including a lack of reconciliation on character changes and insufficient enhancement of sanctions lists.
- How a PEP alert fired but was not escalated properly, ultimately allowing unrestricted activity for 18 days.
- OFSI’s conclusions about screening deficiencies and what could have prevented the breach.
Comsure’s analysis focuses on:
- Screening data quality: poor matching logic (no fuzzy matching) allowed transliteration differences to slip through.
- Insufficient list enhancement: Comsure highlights OFSI’s expectation that higher-risk firms enrich sanctions lists, whether through third-party tools or internal enhancements.
- Process and escalation weaknesses: even after a PEP alert, human and procedural errors delayed the identification of the sanctioned individual.
Read here:-
- https://www.comsuregroup.com/news/ofsi-blog-bank-of-scotland-160-000-sanctions-breach-penalty-key-points/
- https://www.comsuregroup.com/news/ask-mat-can-you-explain-how-the-bank-of-scotland-pep-alert-was-triggered-but-its-sanctions-alert-was-not/
- https://www.comsuregroup.com/news/ask-mat-how-could-the-bank-of-scotland-have-missed-a-sanctioned-russian-pep-even-with-screening-tools/
- https://www.comsuregroup.com/news/160k-sanctions-slip-up-bank-of-scotland-fined-after-name-variation-lets-sanctioned-individual-evade-uk-restrictions/
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.