Practical guide
AML case management vs sanctions case management
Learn how sanctions identity investigations differ from broader AML cases, and how to connect findings without losing evidence, access controls, or decision scope.
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A case is a record of a question and its resolution
Case management organizes findings, evidence, reviewer actions, and decisions. In an AML setting the question may concern customer due diligence, transaction behavior, or a reporting assessment. In sanctions screening the initial question is often whether a returned source candidate is the same identity as the submitted subject.
These investigations can be related without having the same evidence or decision. SanctionsKit’s case review is designed around screening matches and retained results, not a complete transaction-investigation or SAR-filing system.
Keep findings linked, not merged into one label
A customer may have several screenings and several source candidates. Record each candidate’s identity outcome separately. A confirmed match in one source should not silently set the status of an unrelated candidate in another source.
When a broader AML case references a sanctions finding, preserve the source case ID, screening ID, rationale, and limits. The receiving reviewer needs to know what was established and what still requires separate analysis.
Separate the identity conclusion from the action
A sanctions reviewer can compare facts and document whether identities match. A separate authorized person may need to determine the applicable restriction and business action. A broader AML team may then consider additional obligations under its own process.
For an invented case, an analyst dismisses a common-name sanctions candidate using reliable identity evidence. That dismissal does not close an unrelated investigation into the customer’s transactions. The two decisions should remain understandable on their own.
Preserve an evidence boundary
Link only information the receiving reviewer is authorized to access. Avoid copying sensitive case material into a broadly visible note or sending full evidence files through notification channels. Some regulatory reporting materials have specific confidentiality requirements that need a separate governed process.
An approved external document reference should identify the repository, record version, purpose, and access owner. A broken or changeable link can undermine the later review even when the case itself remains retained.
Design handoffs around ownership
Every escalation should state the unresolved question, required next action, owner, and expected response time under internal policy. “Sent to compliance” is not a complete handoff when several teams share that name.
An independent second reviewer should evaluate the evidence and proposed decision, not simply acknowledge that another analyst clicked a button. Retain disagreements and corrections as part of the case history.
Evaluate software against the specific case type
For sanctions cases, test per-match evidence, source lineage, identity comparisons, reasoned decisions, reuse controls, and monitoring changes. For broader AML cases, separately evaluate transaction investigation, linked-entity analysis, regulatory reporting, and applicable confidentiality controls.
Use the sanctions case-management guide for the first workflow and the AML software checklist to avoid buying a narrow tool under an overly broad assumption.