Three obligations, one check
What the Client Name Screening Tool is.
An application developed to support members in fulfilling compliance obligations related to targeted financial sanctions, terrorism financing, and the proliferation financing of weapons of mass destruction. It is primarily designed to screen names against the United Nations Security Council Consolidated Sanctions List, which contains all individuals, groups, undertakings and entities subject to UN Security Council sanctions measures — and screens in the same pass against the OFAC, UK, EU and China lists and the OpenSanctions politically exposed persons dataset.
Alongside sanctions screening, the Tool assesses each match with AI and searches publicly available information to identify adverse news and politically exposed persons, consolidating the findings into a client due diligence report.
The Tool began as an Excel workbook driven by macros. It is now a standalone application: you double-click PRAECERNO and it opens in your own web browser, on your own computer. Nothing is installed, no account is created, and after a one-time licence activation it runs completely offline. Your data still lives in ordinary Excel files — Database.xlsx, history.xlsx, clients.xlsx — so nothing is locked away, and upgrading to a new version never touches your clients, history or documents.
Why it was developed
Members face real obstacles in meeting sanctions screening requirements: limited access to affordable tools, the complexity of the lists themselves, and constrained resources. Reviewing the UNSC Sanctions List by hand in PDF form is labour-intensive and prone to human error. The Tool exists as a free, straightforward resource to help firms meet those obligations efficiently and confidently — and, as the AML supervisory framework advances, to help firms demonstrate compliance readiness. A background and summary overview was published in the Hong Kong Lawyer Journal, August 2025.
How it works
Activate once
Register your practice, receive a licence key by email, enter it once. Internet is needed for that minute only.
Load the lists
One button pulls every active sanctions list and the PEP database from source. Refresh weekly or monthly.
Screen
Type names into the table, or paste a block straight from your own spreadsheet. People and companies share one field.
Assess
Open a hit for the official dossier, record true match, false positive or further information required, and write why.
File and repeat
Everything lands in the client's own folder. Set a review schedule and the Tool re-screens by itself.
Key features
Runs on your own computer
A single application that opens in your browser. No installation, no server, no subscription — and after activation, no internet.
Seven lists, one refresh
UN Consolidated in English and 中文, OFAC SDN, UK, EU, China, and the OpenSanctions PEP dataset — updated in one pass, with a date on every card.
Single and batch checking
One name, or hundreds of rows pasted from Excel — suitable for large client portfolios as well as routine due diligence.
Four clear outcomes
True match, potential positive, false positive, or no match found. Optional date of birth, gender and nationality separate same-name cases.
Match overview and dossier
UN priority matches first, then all other lists, with similarity scores. Open any card for every alias, birthdate, passport and address the list holds.
Built-in local AI
A small model runs on your own machine and drafts a verdict with an evidence-based rationale. No account, no subscription, no data leaving the computer.
Client Center
Your whole book in one view: alert counts, a review queue with a days-waiting counter, sorting by solicitor in charge, and a live map of the jurisdictions you act in.
Scheduled screening
Set a job over any group of clients and it re-runs on its own. Unchanged matches carry your decision forward; only a real change comes back for review.
Relationship network
Link clients to family members, directorships and related entities, so a hit on one party immediately shows everyone connected to them.
A KYC folder per client
Passports, resolutions and proof of address filed on your own machine, plus a generated Excel record and a printable dossier.
Audit trail in plain Excel
Every screening ever run, every assessment and every change over time, kept in ordinary spreadsheets you can open and inspect yourself.
AI Due Diligence Report
Optional KYC reports with AI-driven background checks for sanctions, adverse news and PEP status, summarising money laundering and terrorist financing risk.
Requirements for use
Practice Direction P (Table of Mandatory Requirements, subsection 2 “How” (vi) and footnote 2) requires that, where appropriate, members screen clients, beneficial owners and connected parties against the UN Consolidated Sanctions Lists. Members also have a statutory duty to report suspicious transactions involving designated parties to the Joint Financial Intelligence Unit via a Suspicious Transaction Report.
Optional, voluntary, and yours to refuse.
The AI Due Diligence Report function is a supplementary feature designed to assist with enhanced client screening by searching publicly available information. Use of it is entirely voluntary — members may use only the core UN sanctions screening feature without engaging it at all. Firms that do not use it must nonetheless implement their own arrangements to meet sanctions, PEP and adverse media screening requirements.
Two ways to run it
On your own machine
The built-in local AI assesses a match without any network connection. No account, no subscription, and no client data leaves your computer — so the data privacy obligations set out below are not engaged.
On an external AI platform
Optionally, a ready-made due diligence request can be sent to Grok, Gemini, Perplexity or Microsoft Copilot for a wider search of public information. This transmits limited client identifiers off your machine, and everything below applies.
What it searches
Sanctions and watchlist references
PEP status, including family members and close associates
Adverse media relating to financial crime, corruption, fraud and related conduct
Terrorist financing and proliferation financing risk indicators
Results are compiled into a structured due diligence report with citations and source links, to support your overall ML/TF/PF risk assessment.
Professional responsibility
Each firm remains independently responsible for:
Providing clients with a comprehensive Personal Information Collection Statement (PICS) before using the AI Function
Configuring AI platform privacy settings, including training opt-outs
Restricting AI Function use strictly to AML/CTF/CPF compliance purposes
Exercising professional judgment in interpreting results and conducting full client due diligence
Ensuring compliance with all applicable laws and guidelines, including the AMLO, UNSO, UNATMO, PDPO and Practice Direction P
Before using the AI Function, members must carefully review Section 7 (Disclaimer & Purpose of Use of the AI function) and Section 7.2 (Data Privacy and AI Configuration) of the User Guide, which set out data protection obligations, client notification requirements, PDPO exemptions, risk mitigation strategies and platform configuration instructions.
For AI Function users.
What personal data is processed?
When you use the AI Due Diligence Report function, the Tool transmits limited client identifiers to third-party AI platforms:
Never include HKID numbers, passport numbers, residential addresses, or confidential legal matter details.
Where is data processed?
External AI platforms — currently Grok, Gemini, Perplexity and Microsoft Copilot — process data on cloud infrastructure which may be located outside Hong Kong, typically in the United States or other jurisdictions. The built-in local AI processes nothing off your machine.
Your responsibilities
Before using the AI Function, you must:
Notify clients via a Personal Information Collection Statement
The PICS must disclose the use of AI for AML screening; the transmission of personal data to third-party platforms; cross-border data processing; and client rights under the PDPO.
Configure privacy settings on all AI platforms
Disable AI training on client data, document the configurations with screenshots, and review the settings quarterly.
Document your legal basis for cross-border transfer
For example the PDPO section 58 crime prevention exemption, or the section 60B legal proceedings exemption.
Verify AI outputs against the original sources
Review the primary sources cited in Section I: Source Appendix of each Due Diligence Report before making any compliance decision.
Detailed guidance, including sample PICS wording and step-by-step privacy configuration instructions, is provided in the User Guide at Disclaimer 3.2 and Section 7.2. For data protection guidance, consult the Privacy Commissioner for Personal Data at www.pcpd.org.hk.
Read before you register.
Disclaimer on use of the Client Name Screening Tool
The Client Name Screening Tool (the “Tool”) is provided solely as an aid to support members in compliance obligations related to targeted financial sanctions, terrorism financing, and proliferation financing of weapons of mass destruction. The Tool is primarily designed to screen names against the United Nations Security Council Consolidated Sanctions List, which contains the names of all individuals, groups, undertakings and entities subject to sanctions measures imposed by the UN Security Council.
The Tool is intended for reference purposes only and does not constitute legal advice or a substitute for members’ own compliance procedures. While every endeavour is made to ensure that the Tool is accurate, current and of practical utility, no representation, warranty or guarantee is given as to its completeness or reliability.
Any liability for decisions made, actions taken, or outcomes arising from the use of the Tool or reliance on its outputs is expressly disclaimed. Members remain independently responsible for conducting appropriate due diligence and ensuring full compliance with all applicable laws, regulations and professional obligations.
Firms that already have access to commercial screening solutions are encouraged to continue using those existing arrangements, which may offer more comprehensive coverage. Members who do not have access to such solutions, or who wish to supplement their existing processes, are welcome to adopt this Tool as part of their overall compliance framework.
Disclaimer on use of the AI Due Diligence Report function
The AI Due Diligence Report function (the “AI Function”) is an optional, supplementary feature within the Client Name Screening Tool, designed to assist members with enhanced client screening by searching publicly available information for sanctions, politically exposed persons, adverse media, and terrorist financing and proliferation financing risks.
Use of this AI Function is entirely voluntary. Members may choose to use only the core UN sanctions screening feature without engaging the AI Function. The AI Function is provided as a practical aid, particularly for firms with limited resources, and does not constitute legal advice or replace members’ own comprehensive client due diligence procedures.
Important considerations
Data protection. Use of the AI Function involves transmitting limited client identifiers — name, date of birth, gender, nationality — to external third-party AI platforms (Grok, Perplexity, Microsoft Copilot) that process data on servers which may be located outside Hong Kong. This engages obligations under the Personal Data (Privacy) Ordinance (Cap. 486), including requirements for client notification, data minimisation, security measures and cross-border data transfer considerations. Members remain solely responsible as “data users” under the PDPO for ensuring compliance with all data protection requirements when using the AI Function.
AI limitations. AI-generated outputs may contain inaccuracies, omissions or errors inherent to large language models. Members must independently verify all AI-generated findings by reviewing the primary sources cited in Section I: Source Appendix of each Due Diligence Report before making any compliance decisions.
Liability. Any liability for decisions made, actions taken, data protection compliance, or outcomes arising from the use of the AI Function or reliance on AI-generated reports is expressly disclaimed. Members use the AI Function entirely at their own risk and responsibility.
Fourteen questions.
A · About the Client Name Screening Tool
1 · What is the Client Name Screening Tool?
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An application developed to support members in fulfilling compliance obligations related to targeted financial sanctions, terrorism financing, and proliferation financing of weapons of mass destruction. It runs on the member's own computer and opens in an ordinary web browser. It is primarily designed to screen names against the UN Security Council Consolidated Sanctions List, which contains all individuals, groups, undertakings and entities subject to UN Security Council sanctions measures, and screens in the same pass against the OFAC, UK, EU and China lists and the OpenSanctions PEP dataset. In addition to sanctions screening, the Tool incorporates AI-driven searches of publicly available information to identify adverse news and politically exposed persons, and consolidates findings in an AI-generated client due diligence report.
2 · What are the requirements for using the Tool?
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Practice Direction P (Table of Mandatory Requirements, subsection 2 “How” (vi) and footnote 2) requires that, where appropriate, members screen clients, beneficial owners and connected parties against the UN Consolidated Sanctions Lists, which include designated individuals and entities, terrorists and terrorist associates. Members also have a statutory duty to report suspicious transactions involving designated parties to the Joint Financial Intelligence Unit via a Suspicious Transaction Report.
3 · Why was the Tool developed?
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Members may face challenges in meeting sanctions screening requirements, including limited access to affordable tools, the complexity of sanctions lists, and resource constraints. Conducting manual reviews of the UNSC Sanctions List in PDF format is labour-intensive and prone to human error. The Tool was developed as a free, user-friendly resource to help firms meet their compliance obligations efficiently and confidently. As the AML supervisory framework progresses, the Tool also assists firms in demonstrating their compliance readiness. Background and a summary overview were published in the Hong Kong Lawyer Journal, August 2025.
4 · What are the key features of the Tool?
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Runs on your own computer. A single application that opens in your browser, requiring no installation and — after a one-time activation — no internet connection.
Single and batch checking. Supports both individual and batch name checks, suitable for large client portfolios and routine due diligence.
Seven lists, one refresh. UN Consolidated (English and 中文), OFAC SDN, UK, EU, China and the OpenSanctions PEP dataset, updated from source in a single pass.
Straightforward assessment. Every name returns one of four outcomes, with similarity scores and the full official dossier behind each match.
Record keeping. Screening results, assessments and KYC documents are filed per client, creating a clear audit trail for internal reviews or regulatory inspections — held in ordinary Excel files.
Client management. A client book with a review queue, scheduled automatic re-screening, a relationship network and a document folder per client.
AI assessment. A built-in local AI drafts a verdict and rationale entirely offline; the optional AI Due Diligence Report adds background checks for sanctions, adverse news and PEP status.
Any changes to the existing UN Sanctions List are automatically reflected in the Tool. Updates to the UN Sanctions List are also published regularly under “Where do I find lists of designated persons and entities?”.
B · About the AI Due Diligence Report function
5 · Is the AI Due Diligence Report function mandatory to use?
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No. The AI Function is entirely optional and supplementary. Members may choose to use only the core UN sanctions screening feature without engaging the AI Function. Firms that do not use the AI Function must nonetheless implement their own arrangements to meet sanctions, PEP and adverse media screening requirements.
6 · What does the AI Due Diligence Report do?
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The AI Function uses external AI platforms to search publicly available information for sanctions and watchlist references; PEP status, including family members and close associates; adverse media relating to financial crime, corruption, fraud and related conduct; and terrorist financing and proliferation financing risk indicators.
It then compiles the results into a structured due diligence report, with citations and source links, to support your overall ML/TF/PF risk assessment.
7 · What are the main data privacy and confidentiality concerns?
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Using the AI Function involves transmitting limited client identifiers — name, date of birth, gender, nationality — to third-party AI platforms (currently Grok, Perplexity and Microsoft Copilot), which process data on servers outside Hong Kong. This raises PDPO obligations around purpose limitation, security and cross-border processing; client notification and, where applicable, consent requirements; and confidentiality and legal professional privilege considerations.
Your firm remains the “data user” under the PDPO and is responsible for ensuring compliant use of the AI Function.
8 · Do I need to inform or obtain consent from clients?
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You must provide a Personal Information Collection Statement that clearly informs clients that their personal data will be used for AML/CTF and sanctions screening; that limited identifiers may be submitted to third-party AI platforms; that data may be processed outside Hong Kong; and that they have rights of access and correction under the PDPO.
Depending on your circumstances and risk appetite, you may also decide to obtain explicit consent. Your use may, in some cases, rely on PDPO exemptions such as crime prevention or legal proceedings, but you bear the burden of demonstrating that any exemption applies.
9 · How do I disable AI training on my client data?
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You should configure privacy settings on each AI platform used with the Tool, for example:
Grok. Sign in at grok.com → profile icon → Settings → disable data training / use of your content for model improvement.
Perplexity. Sign in at perplexity.ai → profile icon → Settings or Preferences → toggle off “AI Data Retention” / “Use my data to improve the model”.
Microsoft Copilot. Sign in at copilot.microsoft.com → Settings → Account or Privacy → disable “Model training” or equivalent options.
Keep dated screenshots of your settings and periodically verify that the configurations remain in place.
10 · Can I fully rely on AI-generated findings in the Report?
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No. AI-generated content may contain inaccuracies, omissions or hallucinations. The AI Function provides a starting point, but does not replace professional judgment. You must independently verify sanctions matches, PEP identifications and adverse media findings by reviewing the original sources cited in the Report — URLs and access dates — and by checking for more recent or additional information.
11 · What type of client information should I input?
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To minimise privacy risks while supporting effective screening, restrict inputs to essential identifiers only: full name including known aliases, date of birth, gender, and nationality or country of residence where relevant.
You should not input HKID or passport numbers, full residential addresses, financial account details, or detailed confidential case information.
12 · What if my matter involves sensitive or high-profile clients?
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For high-risk or highly sensitive matters — high-value transactions, politically sensitive clients, or cases involving heightened confidentiality expectations — you should consider whether AI-assisted searches are appropriate at all. In some cases, manual screening using trusted databases or local Hong Kong resources may be preferable. Firms should apply their own risk-based judgment and document their approach.
13 · What alternatives do I have if I prefer not to use the AI Function?
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You may use only the core UN sanctions screening function within the Tool; use commercial screening databases from third-party providers; conduct manual checks against official sanctions lists and other reliable sources; or engage external AML/CTF compliance support.
However, choosing not to use the AI Function does not relieve any firm of its AML/CTF obligations.
14 · Where can I find more detailed guidance and support?
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You can refer to the Tool’s User Guide — especially Section 7 (Disclaimer & Purpose of Use of the AI function) and Section 7.2 (Data Privacy and AI Configuration) — as well as the AML/CTF resources and Practice Direction P, and PCPD guidance on AI and data protection.
For queries or support, contact the AML Team at aml@hklawsoc.org.hk or 2846 8804.
Request access to the Tool.
Please complete this form to provide your practice details and confirm your understanding of the disclaimers. The information collected will be used to deliver the Tool and to keep you updated regarding relevant changes. All responses will be handled confidentially.