Guide to Global Watchlist Searches

Including a global watchlist search during pre-employment screenings can help mitigate the risk of hiring sanctioned or potentially high-risk candidates, like those banned from working in sensitive industries, like finance, or from doing any business in the United States.  In this guide we’ll take a closer look at what a global watchlist search is and how they help protect employers.

A global watchlist is a series of government and regulatory databases that compile information about individuals and entities that are considered high-risk due to suspected or confirmed involvement in illegal or dangerous activities, such as terrorism, money laundering, fraud, or drug trafficking. Global watchlists are made up of domestic and international criminal watchlists, government sanctions, and industry-specific watchlists, including information from the United States, United Kingdom, European Union, and United Nations.

A global watchlist search is often included as part of comprehensive criminal background check to protect a company’s finances, employees, customers, and reputation. Certain types of global watchlist checks are required in regulated industries, like healthcare and finance. Without this important step in the hiring process, organizations could put themselves at risk for major fraud, severe criminal activity, penalties, or legal issues. 

Here’s a closer look at some common types of global watchlist screenings: 

Government watchlists include both sanctions lists and “most wanted” lists from the FBI, Interpol, ICE, and other domestic and international government agencies. Individuals that appear on these lists are often fugitives suspected of committing serious crimes, like money laundering, violent crimes, or terrorism. They may also be subject to global sanctions measures, including travel restrictions, or prohibited from doing business within a certain country. Common government watchlists include:

• US Federal Bureau of Investigation (FBI) Most Wanted Lists
• US Bureau of Industry and Security Denied Persons List
• Interpol Red Notice List
• Office of Foreign Asset Control’s (OFAC) Sanction Lists
• US Drug Enforcement Administration’s (DEA) Wanted Fugitives
• US Immigration and Customs Enforcement (ICE) Most Wanted List

Employers may choose to search industry-specific watchlists when hiring for roles in highly-sensitive industries, such as healthcare and finance. Individuals named on these global watchlists have likely been sanctioned or prohibited from working due to major violations, license infraction, or criminal activity. Common industry-specific watchlists include:

• Fraud and Abuse Control Information System (FACIS)
• US Department of the Treasury’s Specially Designated Nationals (SDN) and Blocked Persons
• Federal Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE)
• System for Award Management (SAM) database
• State-specific Medicare and Medicaid data (where available)

International watchlists vary widely by country, region, and organization, but typically include names of individuals with restrictions like financial, travel, and trade sanctions imposed by foreign governments and organizations like the United Nations. Common international watchlists include: 

• United Kingdom Sanctions List
• United Nations Security Council Consolidated List
• European Union Consolidated List of Persons, Groups, and Entities Subject to Financial Sanctions  
• Australian Government Department of Foreign Affairs and Trade Consolidated List

The most common global watchlist search is generally a sanctions list search. Sanctions lists are maintained by governments and international organizations, such as the US Department of the Treasury’s Office of Foreign Assets Control (OFAC), to identify individuals and entities subject to economic or trade restrictions due to their involvement in activities like terrorism, human rights abuses, or illegal trade.

Sanctions list searches are often the primary and most frequently used global watchlist search because compliance with these lists is legally required for businesses operating internationally. Failing to screen against sanctions lists can result in legal and financial penalties, making them central to anti-money laundering (AML), counter-terrorism financing, and general regulatory compliance programs

The information included in global watchlist searches varies, depending on the list being searched. For example, the FBI’s Most Wanted List and Interpol’s Red Notice List both include fugitives wanted for serious crimes like terrorism, but don’t feature information about sanctions.

Here’s a closer look at what typically shows up during a global watchlist search:

• Criminal activity: Global watchlists typically include individuals suspected or known to have committed terrorism, narcotics trafficking, major international crimes, or fraud. The lists often include information about suspected and known crimes, last known whereabouts, and aliases.
• Sanctions and exclusions: Government and industry-specific sanctions lists show individuals subject to sanctions, debarments, or exclusions from working in the US. or in certain industries, like finance and healthcare. They also show financial restrictions, travel bans, and other types of government and industry restrictions.
• Disciplinary actions: Individuals who have faced disciplinary actions or sanctions from regulatory bodies show up on certain global watchlist checks, like healthcare sanctions lists. 

Conducting global watchlist checks can help employers mitigate risk by identifying individuals who may pose a threat to the organization or face restrictions to work in certain industries or countries. 

Global watchlist searches typically include domestic and international “most wanted” lists, which report information not found on national or county criminal records checks. Individuals on these lists are typically involved in serious crimes like terrorism, money laundering, or drug trafficking. They may also be fugitives wanted in the US or abroad and may use various aliases.

In regulated industries, like healthcare or finance, employers are often required by law to ensure an individual isn’t prohibited from working in the industry or currently facing other sanctions. Employers may also check government sanctions to ensure a potential candidate is not barred from doing business in the US. In some cases, hiring a banned individual could cause an organization to lose federal funding, like a contract or grant. 

Employers that conduct background checks must comply with federal, state, and local laws. You may want to consider the following laws before ordering background checks and consult your legal counsel to learn if other background laws and regulations apply to your business.

The Fair Credit Reporting Act (FCRA) is a federal law that establishes legal requirements for employers who perform background checks using a consumer reporting agency (CRA). Under the FCRA, an employer must provide written notification to candidates of their intent to conduct a background check, including a global watchlist search, and obtain the candidate’s written consent before doing so.

In addition, if the results of a background check impact the decision against hiring the candidate, the employer is responsible for following the adverse action process.

Some states, counties, and cities have passed Ban the Box and other fair hiring laws may impact when employers are permitted to ask about a candidate's criminal history or conduct a criminal background check during the hiring process, among other stipulations.

Working with a qualified CRA, like Checkr, to conduct pre-employment global background checks can help you streamline a complex process and navigate hiring laws with greater confidence. Checkr offers multiple screening options to meet the needs of businesses of all sizes, including international checks. Plus, our mobile-optimized platform and automated workflows help make the background check process efficient and transparent for you and your candidates. Get started with Checkr today. 

About the author

Sarah writes about small business topics and corporate communications. She has written on a wide range of topics, including background checks, hiring trends, company culture, and employee training and development. Her work includes educational articles, press releases, newsletters, and employee onboarding collateral.