Using AI to future-proof sanctions screening
Abstract
This paper explores the application of artificial intelligence (AI) in sanctions screening, focusing on how the technology can address the growing challenges posed by increasingly complex regulatory environments, limitations of the traditional rules-based sanctions screening systems, dynamic changes in sanctions lists and the need for greater operational efficiency and consistency in alert handling. The discussion centres on challenges faced by financial services firms in particular, but also by any organisation subject to sanctions compliance obligations. The paper explores how AI, in particular the current capabilities of generative AI powered by large language models (LLMs), can potentially offer significant enhancements to traditional rule-based sanctions screening systems and provide guidance on how an organisation can prepare for the use of AI in sanctions screening. It also outlines the technical, organisational and regulatory prerequisites for successful AI integration, including robust governance, technological maturity, model explainability, transparency and fairness and workforce upskilling. Early adopters are already demonstrating measurable benefits in efficiency and risk detection, signalling that AI is beginning to shift from experimental to practical use in early-adopter organisations. This paper further offers practical strategies for implementation, from defining success metrics to training operations and compliance teams to interpret and challenge AI decisions. It concludes that realising AI’s potential will depend not only on technological readiness but also on alignment with regulatory expectations, cross-functional expertise and strong governance, all of which are crucial to embedding AI into sanctions compliance programmes. This article is also included in The Business & Management Collection which can be accessed at https://hstalks.com/business/.
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Author's Biography
Marketa Piecuchova began her compliance career in 2013 with an international debt collection agency in the UK, gaining extensive experience in the financial sector and the stringent regulatory framework of the UK Financial Conduct Authority. She joined Swiss Re’s Compliance team in 2017, where she was responsible for overseeing the design, documentation and implementation of fraud, sanctions, and anti-money laundering (AML) risk frameworks. For over five years, she served as the business owner of Swiss Re’s sanctions and AML screening tool, overseeing its configuration, performance, and compliance and collaborating with stakeholders to optimise its effectiveness. This role gave her extensive expertise in screening solutions and technologies. In April 2025, she moved into a client-facing compliance role, advising the insurance business directly on compliance matters. While her current role emphasises advisory and stakeholder engagement, screening technologies remain her professional passion.
David Mayo is the Head of Compliance Programme, Policy and Awareness at Swiss Re, where he is responsible for shaping and driving the organisation’s global compliance strategy. In this role, he leads the creation, rollout and continuous improvement of global compliance risk policies and standards, ensuring that they remain robust, future-proof and aligned with regulatory expectations. His remit includes oversight of compliance tools, training programmes and awareness initiatives that embed a strong culture of integrity and accountability across the company, as well as the design of compliance controls. A core part of David’s mandate is ensuring the adequacy and effectiveness of global frameworks for sanctions and anti-money-laundering risk mitigation. He leads the strategy and design of counterparty due diligence screening solutions, ensuring systems that support scalable, efficient and effective risk mitigation. Prior to joining Swiss Re, David held senior roles at a major global bank where he implemented complex workflow systems to support crucial business processes. He also served as a computer forensic expert witness in corporate litigation proceedings, applying technical knowledge to support investigations and legal outcomes.
Daniel Ueltschi is the Head of Compliance Digital and Analytics at Swiss Re, leading a global team that transforms compliance through data-driven innovation and advanced technologies. In this role, he oversees the development and management of Swiss Re’s digital compliance ecosystem, building future-ready tools and analytical solutions that enhance oversight, enable proactive risk management and strengthen organisational resilience. His team drives innovation at the intersection of technology and compliance, advancing automation, improving data quality and delivering analytics that support the prediction, detection and mitigation of compliance risks across key areas such as anti-money laundering, international trade controls, anti-bribery and corruption, insider trading, data protection, fraud and conflicts of interest. Under his leadership, the Compliance Digital and Analytics team has implemented next-generation solutions that modernise monitoring and assurance capabilities, optimise processes and unlock actionable insights through data. By combining compliance knowledge with technological fluency, Daniel and his team help position Swiss Re’s Compliance function as a strategic enabler of trust, transparency and operational excellence.
