McKinsey has a rather generalist and reader friendly take on it that won't break any laws: If you look at their Exhibit 1, "Sanctions" is clearly a contributor

McKinsey has a rather generalist and reader friendly take on it that won't break any laws: If you look at their Exhibit 1, "Sanctions" is clearly a contributor to high risk in AML/CFT models. As your link showed, the Entity List is one of the first sanctions list created with CFT in mind. Source: https://www.mckinsey.com/business-functions/risk-and-resilience/our-insights/flushing-out-the-money-launderers-with-better-customer-risk-rating-models https://www.mckinsey.com/business-functions/risk-and-resilie...