Bastien Collette (Palana): How to future-proof name screening
Bastien Collette, co-founder and partner at Palana, explains why Luxembourg’s professionals must test the efficiency of their name screening tool.
What makes name screening so critical today?
Geopolitical tensions, growing sanctions lists, and intensified regulatory scrutiny have transformed name screening into a strategic control. Relying on a tool just because it’s in place creates dangerous blind spots. The real risk lies in the assumption that presence equals performance. Authorities now demand proof of effectiveness, and they are right to do so. An outdated sanctions list, a match that goes undetected, or an alert dismissed without justification each of these gaps can have real-world consequences. I see this shift every day with our clients in Luxembourg. Professionals used to ask if a tool was compliant. Now, they ask whether it actually works. I always compare it to car brakes: having brakes is good, but you still need to test them regularly. A missed match isn’t just a technical flaw it’s a governance failure. In our current context, it could mean doing business with a sanctioned entity or letting a terrorist financier slip through the net. Authorities are not satisfied with good intentions or static systems, the only acceptable system is one that works efficiently and that works under pressure.
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What do authorities expect from a screening framework?
Supervisors look far beyond the tool itself. They want a complete framework. First, the tool must access up-to-date sanctions and watch lists including UN and consolidated EU lists. Then, it must be smart enough to detect relevant matches without overwhelming teams with noise. That means, amongst others, fuzzy logic, strong configuration, and tested detection capabilities. But the scope must also extend beyond just clients UBOs, signatories, directors and shareholding companies need coverage as well. Just having alerts is not enough; the response process needs to be documented, auditable, and traceable. When I perform AML/CTF health-check, I sometimes discover inconsistencies between what’s written in procedures and what actually happens in real life. That gap creates regulatory risk. Authorities in Luxembourg insist on regular, evidenced testing that includes performance assessments, sample testing, and crash tests. Every alert dismissed must have a justification, and every decision must leave a trace. It’s not about ticking a box; it’s about demonstrating control and effectiveness. And in this climate, a name screening tool that fails silently is more dangerous than not having one at all.
“Testing your name screening tool is like testing your brakes: it’s not optional.”
How does Palana support clients in building robust name screening controls?
Our work starts with understanding how clients currently manage name screening not just what the policies say, but how decisions are made in practice. We review, amongst others, contracts, operational procedures, escalation process and alert-handling protocols, KPIs, and even data quality. The aim is to test the full ecosystem, not just the tool. I often run crash tests to challenge the detection logic: if I input a sanctioned name with a slight variation, does the system still catch it? We also assess how efficiently true positives are escalated and how clearly decisions are recorded. Clients appreciate our independent feedback we offer remediation plans that are both actionable and tailored to their actual risk exposure. The benefit isn’t just technical compliance, it’s giving management confidence that the screening process protects their organisation and their reputation. When professionals realise that name screening ties directly to governance, not just compliance, they become proactive. They stop thinking in terms of software and start thinking in terms of protection and efficiency. In this domain, complacency costs more than upgrades. And the time to act is always before the next enforcement case, not after.