An existing customer has changed its business scope and jurisdictions it deals with. Which are the steps the bank needs to take to manage sanctions compliance risk for this customer?

Collecting updated customer reference data is essential because a change in business scope and jurisdictions alters the customer's risk profile, directly affecting which entities, countries, and transaction types must be screened against applicable sanctions lists and programs.

Screening directors and ultimate beneficial owners addresses KYC ownership transparency but does not reassess which sanctions lists, jurisdictions, or counterparty categories now apply given the customer's changed business activities.

Deploying an independent risk-based test verifies that the bank's screening controls are correctly calibrated for the customer's new risk profile, meeting regulatory expectations for ongoing sanctions program assurance and effectiveness.

PEP and negative media screening are general due diligence controls targeting corruption and reputational risk, not the jurisdiction-specific sanctions exposure introduced by a change in the customer's business scope.