Sanctions screening false positives: a review checklist

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What is a sanctions screening false positive?

A false positive occurs when screening identifies a potential match, but investigation establishes that the submitted subject and the listed party are different identities. A similar name alone cannot resolve that question. An alert still awaiting evidence is unresolved, even when the reviewer suspects it will eventually be dismissed.

Begin by identifying the authority, list, source record, and screening date. An OFAC entry, an export-control entry, and a healthcare exclusion answer different questions. OFAC’s guidance on assessing name matches recommends reviewing the complete listing and comparing the details available about both parties. Read the source coverage guide alongside the original authority entry.

Compare the identity evidence in a consistent order

Work from the facts actually held about the subject. For an organization, a registration number and issuing jurisdiction can be more discriminating than a common trading name. For a person, a known birth date can help distinguish identities, but only at the precision published by the source.

Classify each comparison as supporting, conflicting, or unknown. A blank passport field is unknown, not a conflict. A changed address may reflect a move. Two documents with different issuers are not necessarily inconsistent. The partial-date guide shows why a year and a full date can overlap without being equal.

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.

Synthetic example: the same name with an incomplete date

This example is invented and is not an allegation about a real person. A customer record for Mira Calder contains a verified birth date of 1984-06-18. A fictional source candidate with the same name gives only the year 1984, and no comparable identifier. The date information overlaps; it does not establish either a full-date match or a contradiction.

The appropriate review record would say that the name agrees, the birth year overlaps, and the remaining identity evidence is insufficient. Keep the case open while following the organization’s evidence-gathering or escalation process. Dismissing it because the source does not show June 18 would turn missing information into a false conflict.

Synthetic example: distinguish two organizations

In another invented example, a supplier and a source candidate both use the name Cedar Finch Trading. The supplier has registration CF-2041 and the source has CF-9842, with the same stated registry and identifier type. That is a meaningful difference to investigate. Confirm the provenance, validity, and possible historical use of the numbers before relying on it.

A reviewer may dismiss an identity match when reliable evidence supports that conclusion under the organization’s policy. The decision concerns these two identities and this evidence. It does not establish that the supplier has no other restrictions, ownership concerns, or required diligence steps.

Write a decision that can be reviewed later

A useful note explains the comparison and its limits. SanctionsKit case review keeps open, confirmed, and dismissed decisions distinguishable from the original screening result. A confirmed identity still requires separate consideration of the applicable restrictions and activity.

Use the following synthetic note structure as a starting point. Include only information needed for the decision and retain it under your approved policy. The evidence documentation explains retrieval and export of retained results.

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 the decision when the evidence changes

Do not turn a dismissal into a permanent name-only allowlist. New source facts, a changed subject, or a different matching policy can change the comparison. Ongoing monitoring can return relevant changes to review while retaining the earlier rationale as history.

If the organization determines a valid match, follow its applicable sanctions procedures and current official guidance. Blocking, rejecting, reporting, or proceeding under an authorization are separate legal decisions. A software label cannot choose among them on its own.