The arrival of the SEPA Instant Payments Regulation in 2025 marked an important shift in how financial institutions think about sanctions screening.  

Much of the discussion has focused on one number: 10 seconds.  

That's the maximum time available to execute an instant euro payment from initiation to settlement. Within that window, institutions must complete the checks needed to determine whether a payment can safely proceed.
 

 
Naturally, much of the focus has been on the performance of sanctions screening engines. “Can they screen payments quickly enough to support real-time processing without compromising accuracy?”  

It's an important question. But it's no longer the only factor.  

Instant payments don't just compress the time available to screen a transaction. 
 
They also expose every operational dependency that sits behind that screening decision.  

A payment can be screened in milliseconds. But that screening decision is only as reliable as the sanctions data behind it.  

Three capabilities must now work together  

Supporting instant payments requires three interconnected capabilities working together:  

• Continuous customer-level sanctions screening, ensuring customers remain screened as sanctions lists change. 

• Rapid incorporation of regulatory updates, so newly published sanctions are reflected in production systems without delay. 

• Real-time transaction screening, capable of making screening decisions within the tight time constraints of instant payments. 

Each capability depends on the others. Operationally, they are part of the same workflow.  

Continuous customer screening depends on current sanctions data.
 
Real-time transaction screening depends on current sanctions data.
 
And current sanctions data depends on how quickly regulatory publications can be transformed into trusted, production-ready watchlists.  

The effectiveness of every screening decision starts long before a payment is ever screened.

The hidden challenge is: Screening against the right data  

Every sanctions update follows an operational journey before it becomes available for screening. Regulatory publications need to be identified, changes extracted, entities validated, records approved and updated watchlists published into production.  

Until that process is complete, there is a gap between what regulators have published and what the screening platform is actually screening against.  

Under traditional payment models, that gap was often tolerated. 

With instant payments, it becomes far more significant. 

A payment may be screened in seconds, but if the underlying watchlist doesn't yet reflect the latest sanctions designations, the institution is making real-time decisions using data that is no longer fully current. At the same time, outdated or inefficiently managed watchlists can generate unnecessary false positive alerts, increasing operational workload without improving risk coverage. 

Watchlist management becomes part of the critical path  

This is where watchlist management becomes a significant part of the operational infrastructure supporting real-time compliance. 

Reducing the time between a regulator publishing a sanctions update and that update becoming available for screening is increasingly becoming a competitive capability. 

At Facctum, FacctList helps institutions shorten that operational gap by transforming regulatory publications into validated, production-ready watchlists and refreshing watchlist content every 30 minutes. This helps ensure screening systems operate against current sanctions data rather than relying on lists that may already be out of date. 

Those refreshed watchlists are then applied through FacctView, enabling high-speed transaction screening within the demanding timeframes required for instant payments while maintaining screening accuracy and helping reduce unnecessary alerts.  

Together, they connect two parts of the compliance workflow that have traditionally been managed separately: keeping sanctions data current and screening against that data in real time. 

Looking beyond screening speed  

The SEPA Instant Payments Regulation is simply asking financial institutions to shorten the time between a regulatory authority publishing a sanctions update and that update being available for real-time screening. 

That shift changes the role of watchlist operations. 

Institutions preparing for instant payments therefore need to think beyond screening engines alone. The organisations best positioned for this new environment will be those that connect watchlist management and transaction screening into a single operational workflow - ensuring regulatory changes become screening-ready quickly, and that every payment is evaluated against the most current information available.