Sanctions screening false positives: how to review a match

First decide whether the identity is still uncertain

A false positive is a possible match that review shows is a different person or business. An alert is still unresolved while the evidence is missing, even if you expect to dismiss it. A shared or similar name cannot settle the question on its own.

In SanctionsKit, open Review queue, select the case and inspect each item under Potential matches. If you start with an API response, keep the screening ID with your customer reference. Find its saved result in Screening history.

Identify the authority, list, source record and screening date before comparing the parties. An OFAC list, export-control list and healthcare exclusion serve different purposes. Read the whole authority entry and the coverage guide, so you know what the record actually says.

Compare facts that can distinguish the two parties

Start with facts you can support. For a company, a registration number and its issuing registry may help more than a common trading name. For a person, compare a known birth date at the level of detail the source provides. Do not fill missing fields with guesses.

Describe each fact as supporting, conflicting or unknown. A blank passport field is unknown. A new address might reflect a move. Different ID numbers may come from different schemes and cannot always be compared. The partial-date guide explains why a year can overlap a full date without fully matching it.

• Confirm that the subject and source record describe comparable entity types.
• Check primary names, source aliases, name order, and the reason the candidate was returned.
• Compare available identifiers with their type and issuing authority.
• Compare known dates, countries, and other source facts without filling gaps by inference.
• Read the original record for source status, restrictions, exceptions, and ambiguity.
• Record the remaining uncertainty and the person responsible for the next decision.

Example: the name agrees, but the birth date is incomplete

Mira Calder and the source candidate below are fictional. The name and birth year agree, but the source gives no month or day. That supports part of the comparison without proving the people are the same.

Keep the case open while you gather the next useful fact or ask for help through your team's process. The source's missing June 18 is not evidence of a different birthday. Treating it as a conflict would turn a gap in the record into a reason to dismiss the match.

Example: two companies share a name

In another fictional case, a supplier and a listed candidate both use Cedar Finch Trading. The supplier's registration number is CF-2041; the source record has CF-9842. Both identify the same registry and ID type. Investigate that difference, checking where the numbers came from, whether they are valid and whether either is historical.

A reliable difference can support a different-identity decision under your policy. State which two identities and records you compared. The decision does not answer separate questions about the supplier's owners, other restrictions or unfinished due diligence.

Write a decision another reviewer can follow

Read the displayed evidence and add verified identity facts with their source references when needed. Save a decision for each candidate and explain the facts behind it. Use Additional information for general notes, documents and required business checks. Continue to Review and complete when the case is ready, including any required second-person approval.

SanctionsKit case review keeps open, confirmed and dismissed decisions separate from the original search result. Even a confirmed identity still needs the relevant restrictions and activity assessed before the business action is decided.

The synthetic note below is a starting point, not text to paste into every case. Keep only the information the decision needs, under your approved retention policy. The evidence guide explains how to retrieve and export the saved record.

Synthetic review note
Subject reference: supplier-example-01
Screening and source references: record the actual references
Supporting facts: same organization name
Conflicting facts: different registration numbers from the same registry
Unknown facts: whether either number is historical
Decision: open pending registry verification
Next action: assigned reviewer verifies both identifiers
Scope: identity comparison for the selected source and screening date

Revisit a dismissal when the facts change

Do not treat a dismissed name as permanently safe. New source facts, changed customer details or a new policy can affect the comparison. Challenging a reused decision in SanctionsKit revokes its original rule and reopens retained cases that relied on it. Monitoring can bring relevant changes back for review while keeping the earlier reason in history.

For a valid match, follow your applicable procedure and current official guidance. Whether to block, reject, report or proceed under an authorization requires a separate assessment. The software's identity label cannot choose the legal action by itself.

Frequently asked questions