How to document a sanctions screening decision

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Write for the next reviewer

A good review note explains what was checked, what evidence was compared, and why the conclusion follows. It should remain understandable after the analyst changes teams or the source record changes. “No issue” and “looks different” are not useful substitutes for a comparison.

OFAC FAQ 5 emphasizes evaluating the available identifying information and retaining the reasoning. The note should not imply that OFAC has approved the business’s identity determination.

Identify the exact comparison

Include the internal subject reference and identity version, screening ID, selected sources or package, source record IDs, source versions, and result time. State whether the note concerns a person, organization, vessel, or another entity type.

When a later correction changes the subject’s facts, reference the original and corrected screenings. Do not edit the older evidence into a version that was never actually screened.

Separate supporting, conflicting, and unknown evidence

List the facts that support identity and the facts that distinguish the identities. Explain why the compared fields are meaningful: issuer, date precision, document provenance, or source context. Mark missing or ambiguous information as unknown.

A year-only birth date that overlaps a verified full date is not a conflict. Two identifier values from different registries may not be comparable. Use the partial-date guide and false-positive checklist when describing these limits.

Use a structured note without turning it into boilerplate

The following example is synthetic. It illustrates an unresolved organization comparison, not a real listed party or a required legal form.

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

Reference sensitive evidence carefully

Use approved repositories for original identity documents and record the relevant version and verification context. Avoid unnecessary personal details in broadly visible notes. A checksum can support a document-version reference but does not prove that the document is authentic or that its content is correct.

SanctionsKit stores retained screening evidence and supports notes, text attachments, and approved external document references. The original bytes of an externally referenced document are not copied into the case merely by adding the reference.

Close the identity question and the action separately

When evidence supports confirmation or dismissal, explain the conclusion and its limits, the reviewer, approval where needed, and remaining tasks. A confirmed identity still requires assessment of the applicable restrictions. A dismissal concerns this comparison, not every possible risk associated with the customer.

Keep later challenges and corrections in the history. Align retention with the applicable rules and approved policy rather than relying on the existence of an export button.