Sanctions screening
Every customer is screened daily against the OFAC and consolidated sanctions lists. What a match produces, how it is reviewed, and what a confirmed match triggers.
Every customer — individuals and companies — is screened daily against the sanctions lists, and any entry above the match threshold opens a review. Screening never applies a control by itself. A match becomes a restriction only when a trained reviewer confirms it is the borrower.
Coverage
Coverage is verified before results are trusted. A list that is missing, empty or stale fails the screen and raises an operations incident naming the affected coverage, rather than reporting a day on which nobody matched. A search that returns as many results as the limit allows is incomplete by definition and is never rendered as cleared.
What a match produces
Every returned entry is compared to the customer field by field, and the comparison produces a class rather than a score:
| Field | How it is compared |
|---|---|
| Name | Word sets, against the listed name and every alias. Identical sets are exact; overlap is partial. |
| Date of birth | Full dates equal is exact; same year and month is partial; different is a conflict. A year-only listing can be partial at best. |
| Address | A listed domestic address is partial corroboration; a listing with no domestic address is a conflict; nothing listed is unavailable. |
| Identifier | Always unavailable — sanctions lists carry no identifier to compare against. |
The result is POSSIBLE, or CONFLICT where a field contradicts. It is never graded strong, and that is a rule rather than an outcome: a name comparison cannot establish identity, and a sanctions list carries no identifier that could corroborate it. So there is no automatic confirm and no automatic clear — every entry above threshold reaches a person.
A cleared false positive is remembered against the exact evidence that was cleared, and expires. A borrower who shares a name with a listed person is not re-reviewed nightly, but new or changed evidence dissolves the clearance and the review runs again.
The review
Work routes to a dedicated sanctions review queue rather than to general support, because the review needs trained judgement and access to evidence not every operator should hold. Neither outcome is available to an AI worker: this is one of the decisions policy reserves for a person.
The reviewer sees the customer’s fields beside the listed record’s, a verdict on each row, and the platform’s assessment kept separate from the provider’s own confidence — described in full under reviewing a match. Triage resolves as a cleared false positive or a potential match; determination resolves as cleared or confirmed. Every decision requires a written reason, and carries the version of the evidence the reviewer was shown.
What a possible match does not do
A possible match applies no control. No contact hold, no collections hold, no restriction — it is informational until somebody decides it. Bankruptcy and death notices both pause outreach at intake; this deliberately does not, for two reasons:
- Sanctions obligations attach to money and property moving to a listed person, not to speaking with a borrower. A contact hold is neither a payment block nor a legal freeze, so applying one would cost the borrower something real while doing nothing about the obligation itself.
- At a name-match threshold most hits are false. Restricting every borrower who shares a surname with a listed person would degrade service for a large number of people to no compliance benefit, and would train reviewers to clear findings quickly in order to undo the harm.
What a confirmed match does
Controls follow the determination, not the hit, and are applied as governed operations with their own permissions rather than as a side effect of a screening run: payment and disbursement holds on the account, the filing your compliance function requires, and continued monitoring of the confirmed match.