Sanctions at Speed: How to Bring Sanctions Screening up to Speed With Instant Payments

In this Lucinity webinar, Luke Fairweather welcomed KK Gupta, Founder and CEO of Facctum, to explore a topic with growing urgency: how sanctions screening must evolve to meet the demands of a real-time, politically charged environment. Their discussion covered why outdated systems can’t keep pace, how to redesign screening from the data up, and what it takes to make progress without compromising governance.

Together, they examined why traditional sanctions systems no longer meet operational requirements, what it takes to deliver timely updates across jurisdictions, and where technology is beginning to make a measurable difference. With decades of senior roles at Citigroup and Barclays, KK Gupta offered a deeply experienced, implementation-focused perspective.

Key Insights from the Webinar

The discussion focused on the pressures financial institutions face in handling real-time sanctions, internal data control, and the role of newer technologies in making compliance manageable and meaningful.

Introduction

As the moderator, Luke introduced the session by emphasizing the need to modernize financial crime controls and asked KK Gupta about his background to set the context. 

KK Gupta shared his career history, spanning more than three decades across Citi and Barclays before starting Facctum. He noted that starting Facctum was motivated by seeing firsthand how difficult, costly, and outdated compliance infrastructure had become at scale. Luke further added that effective FinCrime prevention must be an ecosystem effort, and that collaboration between technology vendors and institutions is essential.

What are the primary challenges with screening today?

KK Gupta began by framing the challenge around the increasing speed and volume of sanctions. In the past, lists would update every few days or weeks. Today, they evolve hourly in response to geopolitical tensions, with jurisdictions like the US and EU often diverging. This puts global institutions in a difficult position, trying to remain compliant across multiple regulators with differing definitions and timelines.

In parallel, he noted the growing pressure from instant payment infrastructures, particularly SEPA instant payments in Europe. The expectation of real-time payments across 25+ countries within 10 seconds completely disrupts the traditional batch-based screening workflows. Screening tools and data delivery systems, he argued, are now operating in a world where latency is a liability.

What does data curation mean in this context, and how does it impact risk appetite?

When asked to elaborate on curation, KK Gupta emphasized that institutions need more than raw access to watchlists. Curation means maintaining quality, relevance, and applicability. Financial institutions need tools to deduplicate, reconcile, and align entries across internal and external lists, enabling targeted filtering based on specific customer types or product exposures.

He highlighted that blindly screening against the full spectrum of lists leads to over-screening, false positives, and resource fatigue. Curation enables precision, allowing compliance teams to focus their efforts where they matter most.

What problems in the existing infrastructure led to the founding of Facctum?

Luke probed what drove KK Gupta to create Facctum, and he responded that legacy compliance systems are outdated and overly monolithic. Deployments are slow, costly, and often yield little benefit. He recalled upgrade cycles that took years, cost millions, and left institutions with little new functionality.

His goal with Facctum was to apply modern engineering, cloud-native principles, and operational agility to a field still dominated by slow-moving incumbents. He believes innovation will take time to reach full maturity across financial services, but progress is already underway.

How do you satisfy the GIGO principle when adopting AI?

Luke raised a central concern around artificial intelligence: no matter how powerful the algorithms, they’re only as good as the data feeding them. KK Gupta responded by stressing the importance of starting with the right use cases and not overextending. His team takes an incremental approach. They co-create solutions with clients, thoroughly test AI components, and build in explainability and auditability from the start.

He emphasized that AI rollouts must be responsible, not reactionary. Success hinges on robust controls and transparency. Rather than chasing hype, Facctum integrates AI only where it adds proven, safe, and measurable value.

Can you speak specifically about watchlist management in the context of legacy infrastructure?

Luke invoked the “aircraft carrier” metaphor to describe the weight of historical infrastructure and asked how institutions can modernize watchlist workflows within such environments. KK Gupta explained that even if real-time sanctions data is obtained, within 5 to 10 minutes of a regulator’s release, the bigger challenge is integrating that data into the existing screening systems.

Many institutions still rely on batch processes that delay ingestion by hours, rendering the real-time feed pointless. Facctum’s approach includes ensuring ingestion capabilities keep pace with data acquisition. Otherwise, he warned, institutions risk continuing to process payments for sanctioned individuals simply because their systems aren’t built for speed.

What does real-time sanctions screening require?

Luke distinguished payment screening, which demands near-instantaneous processing, and name screening, which can be done more leisurely. KK Gupta clarified that both need speed, especially when a new designation occurs. If a sanctioned individual is already a customer, banks need to react within minutes, not hours, or risk unknowingly facilitating criminal activity.

He pointed to use cases where a thousand or more designations might be updated at once. Without automation, this scale is unmanageable. Facctum is building systems that can detect list changes, transform unstructured data, and trigger action within minutes.

What is the operational implication of real-time data ingestion for compliance teams?

Expanding on the above, KK Gupta noted that once data is acquired in real time, the next challenge is proving to auditors and regulators that it flows through the compliance stack without delay. This requires visibility, governance, and robust documentation of every stage—from ingest to alert generation.

Without that assurance, institutions remain exposed. Worse still, sanctioned individuals will use the lag to move funds quickly. KK Gupta believes the first 24 to 48 hours after a designation are the most dangerous - and that’s precisely when many legacy systems are still syncing data.

Conclusion

As the discussion closed, Luke pointed to the broader complexities still left unexplored, particularly around the 25% rule and beneficial ownership. He acknowledged that these pressing issues warrant their own session. KK Gupta responded with appreciation for the thoughtful exchange, emphasizing that while political and technological complexities continue to grow, so too do the tools and principles needed to manage them. Overall, the conversation brought to light the importance of ecosystem collaboration, first-principles thinking, and responsible innovation as the path forward.

Summing Up: Key Takeaways from the Webinar

Luke and KK Gupta’s conversation highlighted how institutions need to rebuild their screening capabilities from first principles. Relying on batch-based systems and static data puts firms at risk. Not only the risk of regulatory penalties, but also of facilitating prohibited transactions during the moments when speed matters most. Here are the standout takeaways from this webinar:

1. Speed now defines capability: Real-time or near-real-time updates are essential to meet regulatory expectations and operational needs.
2. Sanctions divergence increases risk: Institutions must manage conflicting regulatory directives across jurisdictions without falling out of compliance.
3. Curation improves quality: Screening against the full list without filtering increases workload and reduces signal quality.
4. Legacy systems create drag: Cloud-native, modular tools reduce cost, improve agility, and enable institutions to iterate more frequently.
5. Explainable automation is the only path forward: Screening systems must be transparent, auditable, and responsive to both internal and external scrutiny.
6. Institutions must act during the first 24 hours: This period is the highest-risk window for sanctioned entities to move funds.
7. Static customer monitoring is not enough: Real-time awareness must include customer profiles, not just payment flows.
8. The technology exists, but it’s the execution that matters: With structured ingestion, contextual alerting, and modular tools, the potential is already here. The challenge is how institutions use it.

Watch the full webinar recording here for more details: https://youtu.be/ha-qvlMlfuY?si=FTky3UJjOkuD_QBM 

Meet the Speakers

KK Gupta

Founder & CEO | Facctum

With more than 30 years of experience at Citi and Barclays, KK Gupta has led global compliance technology programs at scale. As the founder of Facctum, he focuses on creating flexible, modern tools that help institutions respond to fast-moving regulatory changes, complex screening demands, and fragmented data environments.

Luke Fairweather

Customer Strategy & Success | Lucinity

At Lucinity, Luke helps financial institutions build intelligent, scalable financial crime operations. With a background in product strategy and compliance systems, he focuses on solving real problems through technology that adapts to each institution’s structure and goals. As moderator, he led a grounded discussion that linked operational needs with practical innovation strategies.