How to document a sanctions screening decision

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Write for the next person who will read the case

A useful sanctions decision note lets another reviewer follow the comparison without calling its author. In SanctionsKit, open Review queue in the dashboard, select the case and confirm the current screening and candidate. Explain which identity was assessed and what the evidence supports.

Keep the screening ID, source record and source version with the note. If an identity correction replaced the case, record a new decision against the active work. An old note still describes the old comparison; do not make it appear to cover facts that arrived later.

Put identity evidence beside the candidate

Use Add match evidence for facts that support identity, conflict with it or leave it uncertain. Say where each fact came from and why it can be compared. Use a case note or text attachment for wider context. Those notes do not automatically change the candidate's evidence assessment.

For an original document held elsewhere, link the approved storage location, document version, origin and verification status. The link does not copy the original file into the case. Keep sensitive originals in approved storage and avoid adding personal detail the review does not need.

Explain agreement, conflict and missing facts

List what supports the match and what distinguishes the parties. A difference is useful only when the fields can be compared. State the ID issuer, date precision and source context where those matter. Mark a missing or ambiguous fact as unknown.

A full birth date can agree with a source year without proving the month and day. ID values from different registries may not conflict. Use the date guide and false-positive checklist to make these limits clear in the note.

Use a structure, then write the facts of this case

The synthetic note below shows an unresolved company comparison. It is neither a real listed party nor a required legal form. Replace every example fact with the actual evidence and question in your case. Reusing the headings can help; reusing an unsupported conclusion cannot.

Use a structure, then write the facts of this case code example

Synthetic sanctions review note
Subject: supplier-demo-27, identity version 3
Screening: retained screening reference
Candidate: source, record identifier, and version
Supporting evidence: similar legal name
Conflicting evidence: different registry numbers; issuer confirmed comparable
Unknowns: whether the candidate number is historical
Evidence: approved registry-record reference and version
Identity decision: open pending historical-record verification
Rationale: current evidence does not settle the identifier history
Next action: assigned reviewer obtains historical registry evidence
Second review: required before final disposition under internal policy
Business action: recorded separately by the authorized decision-maker
Revisit triggers: corrected identifiers, changed source facts, policy change

Save the identity finding and business action separately

Different person or entity describes the comparison with this candidate. It does not say the customer has no other risk. Same person or entity still leaves the relevant restrictions and activity to assess. Record the business action and its reason as a separate decision.

If identity is unresolved, name the fact needed and leave the case open. Finish required outside checks before submitting. Where required, another eligible reviewer must approve it. API keys cannot write or approve these human conclusions.

Reopen the saved record and check it

After submission, read the saved candidate decision, reason, business action and approval state. Retrieve the screening evidence and case report through the evidence guide when your records process calls for it. Verify what was saved, not just what you remember entering.

Ask a permitted colleague to follow the comparison from that record. Check that document links still open the intended versions. The audit-trail guide helps test the whole path from original request to later approval.

Example: explain why different dates matter

In a fictional case, the customer and source candidate have the same name. The customer's verified birth date is in 1991; the source gives one definite date in 1962. The reviewer links both records, checks for alternatives or uncertainty, and explains why the reliable difference supports a different-identity decision.

The note also limits the finding to that source candidate. It does not assess other parties, ownership or transaction rules. If the source date were approximate or one of several alternatives, the same dismissal wording would hide a gap. The note must explain that uncertainty instead.

Sources and references

Authority and technical sources

SanctionsKit documentation

SanctionsKit: evidence documentation

Frequently asked questions

What should a sanctions decision note include?

Identify the customer, candidate and screening, then explain supporting facts, conflicts and unknowns. Link the evidence, state the identity decision and record the separate business action. If work remains, name the missing fact and next owner.

Is 'false positive, name only' enough explanation?

Usually it leaves out the evidence that distinguishes the identities. State which facts were compared, where they came from and why they support dismissal. A similar name alone explains why review began, not why it should end.

Does linking an original document upload it into the case?

No. An approved external document reference points to the original in your storage service. Keep the intended version available there under your access and retention rules. The case note should explain why it matters.

Should a decision note mention facts that are still unknown?

Yes, when those gaps matter to the conclusion or next action. Missing evidence should not look like a conflict or a completed check. State the specific question that remains and who will resolve it.