A historical review or lookback is warranted when previously unidentified data elements, missing reference data, or newly discovered customer attributes are detected that may have impacted earlier screening results. Sanctions and Compliance Domains explain that such scenarios indicate that past alerts may not have been correctly generated or evaluated, necessitating a retrospective review.

Routine list updates or daily refreshes do not automatically trigger lookbacks. New sanctions programs may require enhanced forward-looking monitoring, but only missing or newly uncovered data affecting past screening results justify a historical lookback.

Requirements for lookbacks when gaps in screening data are discovered.

Identification of previously missing identifiers as a trigger for retrospective review.