Sanctions checks that keep up after the deal starts

Most sanctions checks happen once, when you take a customer on. You search the name, it comes back clear, you file the result and get on with the deal.

The trouble is that the list doesn’t stand still. The Australian Sanctions Office in DFAT maintains the Consolidated List and updates it regularly. A customer who was clear when you first checked can be added while you’re still acting for them, and a clear result from months ago won’t tell you.

What Curlew does now

• •Curlew checks DFAT for a new version of the Consolidated List twice a day, and loads it automatically.
• •When a new version appears, Curlew re-screens every active customer in your business against it. There’s no button to press, and it’s included on every plan.
• •Customers you’ve already reviewed and cleared as a false positive aren’t raised again for the same name.
• •If a re-screen finds a new potential match, your admins and compliance officer get an email and your dashboard shows the customers to review. The email doesn’t name the customer or the listed person — you sign in to see who it is.
• •If nothing new turns up, there’s no email. Your dashboard just shows that the list was updated and your customers were re-screened.

A clear result is only true on the day you got it. Re-screening is what keeps it true.

A recent example

On 23 October 2026, DFAT updated the Consolidated List after new sanctions designations relating to North Korea. Curlew picked up the new version at its next scheduled check that afternoon and re-screened every active customer of every business against it. Nobody had to do anything.

What it doesn’t do

• •It checks the DFAT Consolidated List only — the list of people, entities and vessels sanctioned under Australian law. It doesn’t check other countries’ sanctions lists.
• •It doesn’t re-screen customers whose relationship with you has ended, or customers already confirmed as a match, because those have already been dealt with.
• •It doesn’t decide anything for you. A potential match is a name to look at, not a conclusion. If you do find a match, DFAT’s advice is to get legal advice before you deal with that person, entity or vessel, or any of their assets.

Where you’ll see it

• •Your dashboard shows when the list was last updated and how many customers were re-screened.
• •Each customer’s Sanctions screening panel shows “Re-screened automatically”, with the date and the list version used.
• •The screening record you download for your file notes that the screen ran automatically when DFAT published a new version of the list.

If you already use Curlew, there’s nothing to switch on — it’s already running. If you don’t, this is one of the jobs Curlew takes off your desk: your customer records, risk assessment and DFAT sanctions screening in one place, with the screening kept current for you.

curlewcomply.au · Curlew Comply is a software tool and does not provide AML/CTF advice. Check thresholds and timeframes against AUSTRAC’s current guidance.