Is it time for basic email surveillance?

In an awful lot of the large dollar OFAC settlements, the decision to evade sanctions ends up getting discussed over email. Why shouldn’t firms implement email surveillance of a very limited set of terms – like Iran, Cuba, and North Korea? If firms can identify and put a kibosh on sanctions evasion schemes as they move towards concrete plans to violate regulatory requirements, they could save a lot of trouble and money.

If you keep the list of terms small, you would keep the number of false positives to as minimum – how many people send emails about Iran, other than in a Sanctions context?

What do folks think?

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